Filing 51874 – COMPLAINT AGAINST THE ELECTRIC RELIABILITY COUNCIL OF TEXAS, INC AND REQUEST FOR GOOD CAUSE EXCEPTION

COMPLAINT OF DGSP2, LLC AGAINST THE ELECTRIC RELIABILITY COUNCIL OF TEXAS, INC. AND REQUEST FOR GOOD CAUSE EXCEPTION COMES NOW, DGSP2, LLC (“DGSP2” or “Complainant”) and pursuant to P.U.C. PROC. R. 22.251,1 brings this complaint (“Complaint”) against the Electric Reliability Council of Texas, Inc. (“ERCOT”), and requests that the Public Utility Commission of Texas (“Commission”) find that ERCOT violated the ERCOT Protocols2 and that the Commission order ERCOT to re-compute settlement data and clearing prices for February 15 and 16, 2021, and order ERCOT to resettle markets to include these price corrections for February 15 and 16, 2021. Additionally, given the urgency ofthe matter and the potential magnitude ofthe issues associated with this docket, DGSP2 respectfully requests that the Commission issue a good cause exception to the requirement that DGSP2 first enter into alternative dispute resolution with ERCOT prior to filing this Complaint. In support of this Complaint and Motion, DGSP2 respectfully shows the following: …