Request Summary
FS Deadline Extension for Software Failures + FS Deficiency Charge Clarifications
Co-sponsors
Description Of Issue
Tariff & BPM 107: The calculation of Forward Showing (FS) Deficiency Charges is dependent on a FS Year and does not contemplate the situation where there is both a Non-Binding Season and a Binding Season in a FS Year. This modification to the Tariff and to BPM 107 will provide guidance on the calculation of FS Deficiency Charges for such scenarios.
Tariff & BPM 108: The current WRAP Tariff does not contemplate time extensions for software outages that impact Forward Showing and Cure Period deadlines. This modification to the Tariff and BPM 108 will provide for an extension of time for Participants to make Forward Showing and Cure Period submissions in the event of Forward Showing software system outage.
Proposed Solution
Tariff & BPM 107: WPP proposed for the Tariff and BPM 107 to be modified such that if a Non-Binding Summer Season is followed by a Binding Winter Season, for the purposes of calculating the maximum Monthly Deficiency for Winter, the maximum Monthly Deficiency for Summer is considered to be 0 MW. Since FS Deficiency Charges are calculated for a FS Year which starts with a Summer Season, there is no change needed for a Binding Summer Season followed by a Non-Binding Winter Season.
Tariff & BPM 108: WPP proposes for the WRAP Tariff and BPM 108 to be modified to include a provision for extending Forward Showing and/or Cure Period deadlines in the event of a Forward Showing software system outage during the final seven (7) days prior to the applicable deadline. WPP proposes to extend the Forward Showing or Cure Period deadline by a commensurate time period in which the software outage occurred. For example, if during the final seven (7) days prior to a deadline the Forward Showing software system was unavailable for two (2) days, the Forward Showing or Cure Period deadline would be extended for two (2) days. If the outage occurred for five (5) days, the deadline would be extended by five (5) days. Additionally, for outages that occur prior to the Forward Showing deadline, WPP would be granted an extension for validating Forward Showing Submittals for the commensurate number of days that the outage persisted.
Specific Document And Language
Complete edits were made to WRAP Tariff, BPM 107, and BPM 108 and will be discussed at the 6/10 PRC meeting.
Suggested Language Update
N/A
Benefits
Tariff & BPM 107: This will align the written policy with the intention of the FS Deficiency Charges and decrease potential gaming opportunities.
Tariff & BPM 108: If a Forward Showing software system outage were to occur during the final seven (7) days prior to a Forward Showing or Cure Period deadline, Participants will have an opportunity to continue their Forward Showing Submittal during the extended time period and will therefore avoid harm. WPP will also receive an extension for FS Submittal validations for an outage that occurs prior to the Forward Showing deadline.
Data Or Information
Tariff & BPM 107: Without changing this language, there are potential gaming opportunities that could incentivize Participants to artificially inflate a Summer Season FS Deficiency in order to minimize the Winter FS Deficiency Charge. This change is in line with intended policy and is an edge case that was erroneously excluded.
Tariff & BPM 108: Without providing a time extension for Forward Showing software system outages, Participants that had not yet completed their Forward Showing Submittal or had remaining deficiencies during the Cure Period could be exposed to deficiency charges due to no fault of their own. WPP is attempting to mitigate this risk by providing a deadline extension if such a software outage were to occur during the final (7) days prior to a deadline.