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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: …

Texas’ utility regulator had an opportunity Friday to eliminate some of the $16 billion that the state’s the grid operator erroneously overcharged power companies during last month’s deadly winter storm — but the board of the Public Utility Commission chose not to do so.

Some Texas electricity customers could have benefited from a decision to readjust the electricity market prices for the week of the storm, according to PUC Chair Arthur D’Andrea and some independent analysts. But other customers could have been …