1. Draft Dispute NPRR and NPRR 75 A comparison for COPS

2. Overview Draft NPRR is focused on the Dispute Process NPRR 75 focuses on the entire Settlement process

3. 9.14, Settlement Dispute Process NPRR 75 Makes numerous minor edits throughout the entire section. Draft NPRR makes numerous, substantive edits to dispute process discussed previously. –20 Business Days Before the next scheduled Settlement Statement due date to be included on statement for RTM –Changes to required items for dispute –Process for filing additional information –DAM Disputes due 10 days after the DAM settlement statement (still constrained by 2% rule, even if accepted) –May require additional comments from ERCOT staff regarding dispute statuses

4. 9.1.2 Settlements Calendar Draft references disputes of Operating Days; deletes reference to timely disputes. NPRR 75 adds requirements for Calendar to include payment due dates and invoice posting dates for late fees, uplifts, CRR Auction Invoices, CRR Auction Revenue Distribution Invoices, and Payments for CRR Balancing Account Invoices

5. NPRR 75: 9.1.4 Settlement Statement and Invoice Timing Settlement Statements and Invoices now must be published by 2400 of scheduled publication date. Previously, it was the due date.

6. NPRR 75: 9.2.5 & 9.5.6, DAM &RTM Resettlement Statement Deletes reference to a Resettlement due to “significant errors”

7. NPRR 75: 9.4.1: Invoice Recipient Payment to ERCOT for the DAM and 9.4.2, ERCOT Payment to Invoice Recipients for the DAM Switches Business Days and Bank Business Days Additionally, 9.4.2 deletes ERCOT requirement to calculate the amounts available for distribution to Invoice Recipients by the next Business Day. Still maintains requirements that the amounts to remit must be “available for payment” under 9.4.3, Partial Payments … for the DAM

8. NPRR 75: 9.4.3, Partial Payments by Invoice Recipients for the DAM Excludes payments for RMR service and amounts calculated for the CRR Balancing account from short payment reductions Does the Business Day Switch.

9. NPRR 75: 9.4.5, Late Fee and Late Fee Invoices for the DAM Adds two-day, two-step invoice process to DAM Late Fee Invoices The Business Day Switch

10. Draft NPRR: 9.5.6, RTM Resettlement Statement Significant Changes, deleting references to disputes in the Resettlement Section, except for giving requirements for a dispute of a RTM Resettlement Statement and how a dispute following a final statement can trigger a resettlement.

11. NPRR 75: 9.6, Settlement for the Real-Time Market Adds requirement that RTM Invoices be based on RTM Statements. Adds attributes to RTM Invoice (name, ERCOT identifier)

12. NPRR 75: 9.7.1, Invoice Recipient Payment to ERCOT for the RTM, 9.7.2 ERCOT Payment to Invoice Recipients for the RTM The Business Day Switch Allows ERCOT to withhold payments as a matter of law. Removes Requirement to calculate amounts available for distribution, but maintains partial payment process

13. NPRR 75: 9.7.3, Partial Payments for RTM Allows ERCOT to cease charging late fees earlier than 180 days (sole discretion) Adds section 9.7.3.1 –LRS based on the calendar month three months before the date of uplift invoice. If total short pay exceeds $2.5 MM, late fee invoices are 30 days apart. Adds 9.7.3.2 about two-day two-step process

14. 9.7.5, Late Fee and Late Fee Invoices for RTM Adds RTM Late Fee Invoice attributes The Business Day Switch Allows ERCOT to withhold payments pursuant to common law

15. 9.8, CRR Auction Invoices & 9.9, CRR Invoice Payment Process Adds additional attributes to invoice CRR Auction Invoices must be paid regardless of dispute status Business Day Switch Common law withholding clause

16. 9.10, CARD Invoices, 9.12, CRR Balancing Account Invoices, 9.13, CRR Balancing Account Payment Process Additional Invoice Attributes, Business Day Switch, Common Law Clause

17. NPRR 75 administrative changes 9.1.3 (requires invoice to be on MIS Certified Area, published in XML) 9.2.3, Deletes reference to Day-Ahead RMR Unit Charge on the DAM Settlement Charge type list 9.3 Requires Recipient name and settlement ID on DAM Invoice 9.1.5, 9.2.4, 9.2.8, 9.5.3, 9.5.4, 9.5.5,9.5.6, 9.5.11,

18. Draft NPRR administrative changes 9.2.8, 9.5.2