Today, MISO requires that any Market Participant, including Aggregators, submit a Model Change Request using the Model Editor creating a new DRR object anytime a new DRR is enrolled. As part of this Request, the enrolling MP is required to provide the EP Nodes related to any and all underlying facilities comprising the DRR. However, LBAs are the only MP with direct access to EP Node information for such underlying facilities; ARCs and non-LBA MPs must obtain this information from the LBA prior to proceeding with a Model Change Request. However, there is no explicit requirement for LBAs to provide this information to these enrolling MPs: BPM 026 today only states “LBAs are requested to review and provide important location details (e.g., EPNodes) based on end-use customer addresses” [emphasis added]. In addition, Voltus’ experience is that there is a wide range of capability at LBAs to efficiently access EP Node information - many LBAs are not currently equipped with the ability to access high volumes of EP Nodes based on customer addresses and/or account numbers. Left unaddressed, this provides an insurmountable barrier to enrollment by non-LBA MPs and a meaningful challenge for enrollment by LBAs, particularly in regards to the enrollment of DRRs with many locations (i.e., residential DRRs) for which LBAs cannot efficiently obtain all the necessary EP Node information, or if the relevant LBA simply does not comply with the request by the MP to provide EP Nodes. As MISO progresses in its proposed DR reforms and the DRR product becomes the only instrument by which LMRs can receive energy payments via dual-enrollment, this issue becomes all the more urgent.