Protocol Interpretation Request Submission Process
Market Participants seeking to clarify or interpret the Protocols should use the Nodal Protocol Revision Request (NPRR) process whenever possible. However, a Market Participant or ERCOT may believe that an interpretation or clarification is needed to address an unforeseen situation, and there may not be sufficient time to submit the issue through the NPRR process. If such a case arises, the Market Participant or ERCOT may seek an official Protocol interpretation or clarification, pursuant to Public Utility Commission of Texas (PUCT) Substantive Rule §25.503 (i), Official Interpretations and Clarifications Regarding the Protocols.
The ERCOT General Counsel is responsible for receiving and responding to all Protocol Interpretation Requests (PIRs). ERCOT responds within ten (10) Business Days of receipt of the PIR. ERCOT may take one of the following actions on each PIR:
- Issue an official interpretation of the protocols; or
- Decline to issue an official interpretation of the protocols because the language for which the interpretation is requested is too ambiguous or for another reason.
In the event that ERCOT declines to issue an official interpretation, the requestor is free to use the PRRprocess to propose changes to clarify the Protocols. For further information about the PIR process, please see PUCT Substantive Rule § 25.503(i).
- PIRs must be submitted to ERCOT's general counsel.
- ERCOT shall provide a copy of the PIR to the PUCT staff upon receipt.
- ERCOT will consult with the PUCT staff and appropriate ERCOT staff before issuing an interpretation.
- Official interpretations will be sent to all registered Market Participants in the form of a Market Notice with the appropriate effective date. The interpretations will also be included in boxed language in the relevant section of the protocols.
- Requestors' names will not be identified.
Market participants seeking an ERCOT interpretation of the protocols are free to communicate informally with ERCOT staff. However, the opinion of an individual ERCOT staff member is not an official interpretation of the protocols and may not be relied upon by a market participant as a defense for failure to comply with the protocol or PUCT rules.
PIRs must be prepared using the form below and submitted to ProtocolInterp@ERCOT.com.