Common use of Responsive Pleadings Clause in Contracts

Responsive Pleadings. 271. The Midwest Independent Transmission System Operator, Inc. (Midwest ISO) takes issue with the MRO bylaw provision combining ISOs and RTOs with other transmission operators in representation on the board.152 The Midwest ISO argues that this provision fails to provide separate stakeholder representation for ISOs and RTOs, as required by the ERO Certification Order.153 Specifically, the Midwest ISO points out that in the ERO Certification Order, the Commission required NERC to modify its governance structure to create a separate segment for ISOs and RTOs and to exempt ISOs and RTOs from a provision weighting the vote of segments with fewer than ten members. The Midwest ISO suggests that this ruling, which applied to NERC, should also apply to Regional Entities.