Shell Energy understands various information is required from participants for the Program Operator (“PO”) to calculate uncertainty and holdback requirements for WRAP participants. WPP should recognize required information submitted daily will be unique to each WRAP participant, e.g., for those entities which do not operate their own Balancing Authority, contingency reserve requirements may not be applicable.
In addition, it is Shell Energy’s understanding the results of the multiday assessment will be indicative in nature and not binding; if so, the Ops program timeline business practice document should explicitly clarify this.
April 13, 2023, 12:34 p.m.
NV Energy appreciates the opportunity to comment on the Operations Program Timeline Business Practice Manual (“BPM”) and offers the following comments for consideration. NV Energy provides the following proposed revision to the Multi-Day-Ahead Assessment section:
“If the Multi-Day-Ahead Assessment indicates low risk of a potential Sharing Event, the PO may consider early release of a portion or all of the indicative Holdback Requirement for Participants who have a positive Sharing Calculation result. Additionally, if the Multi- Day-Ahead Assessment indicates a potential for a large Sharing Event, the PO will notify Participants of the potential for insufficient holdback to meet the total deficit as calculated by the Sharing Calculation which.”
April 13, 2023, 1:57 p.m.
April 14, 2023, 8:23 a.m.
Is multi-day-ahead release only for Day + 5-7? The current set up of figure 1 makes it appear so.
Regarding figure 1: Why is the pre-schedule day on Friday at the end of the multi-day data submission. The pre-schedule day is at the beginning of the timeline which would cover Sunday-Monday. Can we add what day it is today to the figure?
April 14, 2023, 8:41 a.m.
- Notification of Holdbacks and Energy Deployments needs to become a ‘push’ notification in the near future, remove the dependency on a participant checking an on-line user interface!
- Pg. 4, Mid-second paragraph - The sentence that starts with, 'Additionally, if the Multi- Day-Ahead Assessment indicates...' is an incomplete sentence. It ends with 'which'.
April 14, 2023, 11:19 a.m.
On page 4, include references to specific files as outlined in Participant Files Specifications document.
On pages 4 and 5, it states that PO may consider early release of holdback. Figure 1 indicates this could happen within a 3 day window before OD, with caption indicating this process will be defined in the BPM (which BPM, this one or another?) Since this BPM covers timelines, the release timeline should be specifically spelled out in the text.
Figure 1 is unclear. Resolve conflicting information on submitting MD assessments and issuing Sharing Calculation results. On page 4 it states MD is submitted only on scheduling days (generally Mon-Fri). However, Figure 1 depicts MD assessments being submitted on Saturday and Sunday. On page 5 it states that interim sharing calculations will be run on ‘interim’ days. Do interim days include Sat & Sun or only scheduling days (Mon-Fri)? Design document states MD data submission occurs ‘each day’.
On page 4, 'PO may consider' is vague language. If PO makes decision to release holdback early, how is this communicated to participants? How is early release reflected in subsequent posted results?
April 14, 2023, 12:05 p.m.
April 14, 2023, 12:25 p.m.
PacifiCorp appreciates the opportunity to provide feedback on the Operation Program Timeline Business Practice Manual (BPM). While PacifiCorp feels the overall BPM is comprehensive, the daily time line for the submittals associated with the operating day seem too long. PacifiCorp would like to see the operating timeline compressed in order to speed up the time between a participants forecast to when results are posted. Market participants need time in order to take action in the bi lateral market while there is liquidity in the bi-lateral market.
April 14, 2023, 1:35 p.m.