Shell Energy recommends the following changes for clarity; it is unclear what is meant by holdback exchange if actual e-tagging occurs later.

Participants are required to provide their final forecast data and complete any holdback exchange at least 120 minutes before the operating hour. The PO will use this data to perform a final execution of the Sharing Calculation, which will be completed at least 105 minutes prior to the operating hour. The results of the Sharing Calculation on the OD are intended to help Participant’s decision-making on the amount of energy to deploy. However, the calculation is indicative because the deficit Participant can claim up to the amount of holdback that they were allocated on the Preschedule Day. Participants must [should endeavor to] tag their Energy Deployments at least 90 minutes before the operating hour.

In addition, the document should discuss situations when energy deployments are E-tagged after T-90.  Would this result in a delivery failure?  The T-90 requirement for E-tagging is quite conservative; tagging activity as late as T-45 to T-20 is observed in markets today.   Shell Energy would recommend setting the soft deadline for E-tagging to T-90 with a hard deadline of T-30.

The BPM proposes that the participant submit hourly data 120 minutes prior to the operating hour and again after the operating hour during each operating day. NV Energy recommends that this data submission only be required when a sharing event occurs, rather than every operating day. It is unclear from this BPM if the process would end once any holdback was released or if it would be the intention of the program to submit hourly data regardless of a sharing event occurring or not. NV Energy understands that this information maybe necessary to update the sharing calculation or to review participation, but recommends it only be collected when a sharing event occurs.

No comments.

Recommend for clarity to change first sentence to “deficit participant final opportunity to accept energy delivery of holdback is at T-120”. Suggest to also identify who is responsible for tagging after the T-120, probably should be deficit entity and, they should communicate accepted energy delivery to the surplus participants real-time desk. 

• Final execution of Sharing calculation completed at 105 minutes prior to Operation Hour.

  Calculation is indicative….

  Participant must tag Energy deployment at least 90 minutes before hour….

  What is the deadline for Participant to claim ‘up to the ab mount of holdback that they were allocated from Preschedule’?

  When is the final notification of energy deployment issued??

  How much time does a participant have to tag deployment between the 105 - claiming – issuance of deployment order – 90 minutes before…   a lot to happen in 15 minutes with NO defined times in the BPM..  These need clarified and set as part of the BPM that is specifically about this timeline.

Final forecast data is submitted through SFTP and holdback is exchanged through PIT, correct?

Tariff defines Energy Deployment as “A delivery of energy that a Participant is required to provide during an Operating Day”.  Be concise with the use of the word ‘deploy’ in this section.

Design document mentions that deficit participants shall confirm need for and amount of Energy Deployment to be called upon, but this step is not specifically addressed in the BPM.  Could be included in Figure 2 as well.

Design document indicates tagging must occur by T-60.  BPM indicates T-90.

1. 1. E-Tagging at T-90 differs from the general way SCL operates. Is it possible to have some added flexibility for Participants E-Tagging their energy deployments to be more in line with standard E-Tagging deadlines followed today, such as T-40 to T-20 timeframe?

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