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3/5/25, 3:45 PM

M-A030525-01 IMPORTANT COMPLIANCE ISSUE: Notice of Widespread Noncompliance with Reporting and Attestation Regarding the Purchase of Critical Electric Grid Equipment (CEGE) and Critical Electric Grid Services (CEGS)


NOTICE DATE: March 5, 2025

NOTICE TYPE: M-A030525-01 Legal

SHORT DESCRIPTION: IMPORTANT COMPLIANCE ISSUE: Notice of Widespread Noncompliance with Reporting and Attestation Regarding the Purchase of Critical Electric Grid Equipment (CEGE) and Critical Electric Grid Services (CEGS)

INTENDED AUDIENCE: All Market Participants registered as of December 31, 2024

DAYS AFFECTED: April 1, 2025

LONG DESCRIPTION: Hundreds of Market Participants have failed to submit an LSIPA Attestation, that is, an initial report and attestation identifying any purchase, lease, or receipt of any CEGE or CEGS that the Market Participant knows to be from a Lone Star Infrastructure Protection Act (LSIPA) Designated Company or LSIPA Designated Country as required by ERCOT Protocols Sections 16.1.4(2)(a)-(b), which implement state law requirements adopted in Senate Bill (SB) 2013 (88R). The information Market Participants are required to report to ERCOT in the LSIPA Attestations is necessary to provide ERCOT with visibility into vital factors that impact grid security and reliability.

There were two deadlines by which all Market Participants were required to submit an LSIPA Attestation.

  • First deadline: ERCOT Protocols Section 16.1.4(2)(a) required each Market Participant to submit an LSIPA Attestation for CEGE or CEGS purchases made after June 18, 2021, to ERCOT by October 28, 2024. 
  • Second deadline: ERCOT Protocols Section 16.1.4(2)(b) required each Market Participant to submit an LSIPA Attestation for CEGE or CEGS purchases made between June 8, 2018 through June 18, 2021, to ERCOT by December 15, 2024.

ERCOT published four Market Notices reminding Market Participants of the LSIPA Attestation deadlines.

All Market Participants that failed to submit either or both of the required LSIPA Attestations must submit the required LSIPA Attestation(s) no later than April 1, 2025. ERCOT will file a list with the Public Utility Commission of Texas in Project No. 55999, identifying all Market Participants that fail to submit the required LSIPA Attestations by April 1, 2025. In addition to filing a list of noncompliant Market Participants, ERCOT reserves the right to take further appropriate action regarding Market Participants who fail to timely submit their LSIPA Attestations.

If you have not submitted an LSIPA Attestation for either deadline, please complete the LSIPA Attestation (Section 23, Form S) attached to this notice and return the executed attestation to ERCOT via email to: LSIPA@ercot.com. Executed attestations must be received by ERCOT no later than April 1, 2025.

Please do not resubmit any LSIPA Attestation you have already timely submitted in accordance with ERCOT Protocols Section 16.1.4(2)(a)-(b). In your submission email, ERCOT requests that each email submission indicate the deadline(s) (October 28 and/or December 15) for which the LSIPA Attestation is being submitted.

ACTION REQUIRED: For Market Participants who failed to submit LSIPA Attestations, submit the past due LSIPA Attestation(s) to ERCOT by April 1, 2025.

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.

If you are receiving email from a public ERCOT distribution list that you no longer wish to receive, please follow this link in order to unsubscribe from this list: http://lists.ercot.com.

 

dg/mm


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