No response submitted.
7.2.1 “may not invoke the Dispute Resolution Procedures to dispute data inputs or to request use of alternative data.” This seems contrary to the intent of the program to ensure that we have the right data and that the data requested/used is appropriate for the intended use. Why would alternative data be unilaterally excluded? Why would data that is in dispute not be allowed to go through the resolution process? Entities need to have the necessary protection in place to ensure we get to the right outcome.
02a: Section 9 Prefer any dispute, without limitations.
Overall, the 90-day window is adequate, but the Tariff should specify whether this period refers to calendar days or business days to ensure clarity. Additionally, in 7.2.1, the term ‘data inputs’ needs to be clearly defined. It should specify if the intent is to allow disputes related to the ‘price formation’ calculation but not other aspects of settlements such as MWhs.
7.2: Final statements like that made in 7.2 do not need to be in the tariff. This should be high-level and point to a BPM. Does 7.2 take into account price revisions in price indexes and CAISO?
No response submitted.
Newly added section 7.2.1 stipulates that a Participant may not invoke the Dispute Resolution Procedures to dispute data inputs or to request the use of alternative data.
It would be beneficial to obtain clarification regarding the input data as it could potentially contain erroneous data.
No comments at this time.