NOTICE DATE: September 17, 2021
NOTICE TYPE: M-A090121-02 Legal
SHORT DESCRIPTION: REMINDER: 2021 Digital Certificate Audit Attestation (DCAA) Due by October 1, 2021
INTENDED AUDIENCE: Market Participant (MP) User Security Administrators (USAs)
DAY AFFECTED: October 1, 2021
LONG DESCRIPTION: In September 2021, each MP must generate a list of its registered USA and Digital Certificate Holders for each MP registration type, by DUNS number, and perform an audit thereof to ensure compliance with the ERCOT Protocols. For example, if an MP is registered with ERCOT as a Qualified Scheduling Entity (QSE), Congestion Revenue Rights Account Holder (CRRAH), and a Load Serving Entity (LSE), then that MP must submit three separate DCAA forms—one for each registration type. Completed DCAA forms must be submitted to ERCOT by October 1, 2021. See ERCOT Protocol Section 16.12.3(2) and the Market Participant Identity Management (MPIM) Digital Certificate User Guide.
You are receiving this Market Notice because you are the USA for an MP. As the USA, you are responsible for registering all Digital Certificate Holders of the MP through ERCOT’s computer systems and administering the use of Digital Certificates for access to ERCOT’s computer systems on behalf of the MP. Please use the DCAA form found in the ERCOT Protocols (Section 23, Form L) to verify compliance with USA and Digital Certificate audit requirements under the ERCOT Protocols.
If an MP cannot comply with the October 1, 2021 deadline at the time the audit requirement first applies to the MP, then the MP must request an extension by providing ERCOT a written explanation of why it cannot meet the deadline. The explanation must include a plan and timeline for compliance not to exceed six months from the original deadline. ERCOT shall review that extension request and notify the MP if the request is approved or denied. ERCOT may approve no more than one extension request per MP. See Protocol Section 16.12.3(3).
On or about December 15 of each year, ERCOT must report to the Public Utility Commission of Texas (PUCT), all MPs that have failed to (a) properly perform the requisite Digital Certificate audits, and/or (b) comply with Protocol Section 16.12.3. See Protocol Section 16.12.4(2). If an MP fails to properly perform the requisite Digital Certificate audits and/or fails to comply with Protocol Section 16.12.3, ERCOT can disqualify the MP’s USA and/or revoke any/all Digital Certificates assigned by that USA after ERCOT provides notice to the noncompliant MP and the PUCT, subject to Protocol Section 16.12.4(4). See Protocol Section 16.12.4(3).
ACTION REQUIRED: In September 2021, each MP must generate a list of its registered USA and Digital Certificate Holders for each registration type, by DUNS number, and perform an audit thereof. Completed DCAA forms must be submitted to ERCOT by October 1, 2021.
Once all corrections/changes have been made to the list, the MP is responsible for submitting to ERCOT signed DCAA forms for each MP registration no later than October 1, 2021. Please use the form found in the ERCOT Protocols (Section 23, Form L) for verifying compliance with USA and Digital Certificate audit requirements under the ERCOT Protocols. Please further note that with respect to documents requiring signature under the ERCOT Protocols, the Texas Uniform Electronic Transaction Act (TUETA) provides: “If a law requires a signature, an electronic signature satisfies the law.” Tex. Bus. & Com. Code § 322.007(d). This law only applies to transactions between parties that have both agreed to transact electronically. To satisfy a signature requirement under the Protocols (not otherwise requiring notarization), ERCOT has accepted, and will continue to accept, electronic signatures and scanned copies of documents containing wet signatures. Please submit DCAA forms via email to DCAA@ercot.com.
CONTACT: If you have any questions, please contact your ERCOT Account Manager. You may also call the general ERCOT Client Services phone number at (512) 248-3900 or contact ERCOT Client Services via email at ClientServices@ercot.com.