More RSIF follow-up
Meetings were held last week to take up the resolution of four
outstanding issues from the RSIF workshop. Attached are materials from
the meetings:
RQQIOUT2.DOC - draft outline and workplan of the Data Quality and
Integrity report
DISPOUT.DOC - draft outline and workplan of the Dispute Resolution
report
METER.DOC - notes from the meeting on meter registry information
UINOTES.DOC - notes from the Universal Identifier meeting
UNIVID2.DOC - proposal from the CEC on Universal Identifiers
MATRIX3.DOC - matrix of market risks and potential recommendations
MATRIX.XLS - matrix of dispute types and existing procedures
MATRIX2.TXT - descriptive gap analysis for dispute resolution
You are invited to comment on any and all of the documents. Please
also be advised of the schedule of subsequent meetings (all will be held
at PG&E facilities in San Francisco - exact location tbd):
Data Quality & Integrity
Thursday, September 18, 9-12
Thursday, September 25, 9-12
Thursday, October 2, 9-12
Dispute Resolution
Thursday, September 18, 1-4pm
Thursday, September 25, 1-4
Thursday, October 2, 1-4
Meter Registry Information
Friday, September 19, 9-12
Friday, September 26, 9-12
Friday, October 3, 9-12
Universal Identifiers
Friday, September 19, 1-4
Friday, September 26, 1-4
Friday, October 3, 1-4
First drafts will be circulated on September 30, with the final report to be
submitted to the CPUC on October 10. Your participation is strongly
encouraged as it is critical to the strength of the proposals contained in
these reports.
Toby Tyler
PG&E
(for the participating stakeholders)
Attached is a draft of the matrix of sample disputes and existing dispute resolution mechanisms (sheets 1 and 2). Please be prepared to comment on this at our Thursday meeting.
In the dispute resolution chapters in the ISO and PX tariffs (basically the same language in both places) there is a lot of meat there as to the process for ADR -- I recommend a brief skim to all. In a
nutshell: there is a mediation round (with a mediator chosen from an ISO
appointed list), and then, if no settlement is reached, mandatory binding
arbitration (again, with an arbitrator selected from a third party appointed
list). Parties may also elect to use so-called "baseball arbitration" rules
by mutual agreement (each party lays down its "last best offer" and the
arbitrator chooses one or the other offer but may not invent any compromise in
between). Decisions of an arbitrator have the force of FERC decision and may
only be appealed on limited procedural (not factual) grounds.
Where there is less detail available is on the specific kinds of disputes that
will be subect to ISO ADR rules (Is this something we could make
recommendations or ask the PUC/FERC for clarification on?). While inter-SC,
UDC/ISO and SC/ISO squabbles are clearly covered, ESP/ISO disputes are a grey
area, and an ESP dispute with an SC or MDMA (with which the ESP may or may not
do business directly) is probably well outside the ISO Tariff's reach.
Similarly, the PX dispute rules are clearly applicable to UDC and ESP
settlements at the PX, but not necessarily to disputes involving non-PX SCs or
ESPs.
On the "retail" side, it appears that the UDC relationship to the ESP and the
responsibility of the ESP for the performance of all its subcontractors, are
included in both the service agreement and DA Tariff. What is missing from
current versions, however, is any description of the specific ADR mechanisms
that should be utilized when disputes occur. Also, in disputes that arise
AMONG metering agents, MDMAs, and billing agents in the market, it is not
clear whether CPUC metering standards, bilateral contracts with ESPs, or any
other document will contain specific ADR provisions.
In short, I think we may be getting to the beginnings of a "gap analysis"...
(prepared by PG&E)
RDQIOUT2.DOC
DISPOUT.DOC
METER.DOC
UINOTES.DOC
UNIVID2.DOC
MATRIX3.DOC
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