As a general matter, the more time WRAP participants have to assess and react to holdback information from the PO the better.  The timelines generally appear workable; however, some flexibility may be required at times with respect to the proposed timelines on the Ops preschedule day.  Over the past few years, the bilateral markets at Mid-C and Paloverde have trended to trading on exchanges later than in previous years.  Therefore, it may be imprecise for a participant to assess the volume of holdback to request from surplus WRAP members until the markets begin to frame up—some days this happens as late as 7AM PPT (or later).   In other words, it may be difficult for participants to determine if deficiencies can be addressed in-market such that commitment to holdback is required before significant market activity commences. 

It appears the last sentence of the Preschedule Day paragraph on Pg. 6 is not complete.  

It is unclear what is meant in the last sentence of the Preschedule Day section because it was not completed.

No comments.

In the first paragraph, regarding the mention of the Sharing Calculation: This could use some clarification around that the sharing calculation is re-ran but is not going to change holdback requirement. May not need to include the re-run language as the sharing calculation is always re-ran after pre-scheduling day even when it is not before the OD. 

Are participants actually exchanging holdback in the PIT? Would this not be done through phone and deal capture of transactions? 

At the end of this section there is a non-visible Link to timeline, figure 2, should link be visible and say, “presented in...Figure 2”?  

Figure 2 Comments:  

• FS box at 0520 makes it appear you have to submit something related to FS at 05:20. Believe the intent is to just depict that information from the FS 7 months in advance is utilized in the sharing calculation. 

• 2A-2C Submittal & 1A + 1A2 1B Submittal: Transmission submission will be done by participants as automated standard file submission not after posting of results if there is no new information on participant specific deficit to allow for customized points to a specific participant. Voluntary may make sense to have in parallel.  

• What is 1A2 it is not in data spec file? 

• Prior to start of Operating Day: Need an additional box for transmission procurement in SWEDE region by 16:30.  

• After the Fact Data Submission: What is the need for after the fact data submission within two hours of the hour ending? Couldn't this be a daily submission? The timeline doesn’t depict the frequency of submission but is noted in the data specification document at no later than 120 minutes after the hour.  

• Very last sentence in this section is incomplete - seems to drop off and have a random preiod further down. 

On page 5, “Exception to default scheduling practices” is redundant as the WECC calendar take into account holidays and new months.

On page 5, it states that the sharing calc performed on preschedule day is binding, but the PO will rerun sharing calcs on each interim day anyway (i.e., when preschedule day is not day before OD.)  Is this information shared in PIT? What do participants do with interim day information?  How do deficit participants indicate they would like to claim a portion of any voluntary holdback that may be available?

On page 5 in item ii, define/specify what is meant by “information necessary to match surplus Participants with deficit Participants in subregions without a central transmission hub”.  Is this a specific type of file transfer (e.g., PL, PTPL)?  Is this an opportunity to submit information, or is it an obligation?

Also, define/specify ‘subregions without a central transmission hub’.  If this refers only to SWEDE, then state that.

On page 6 in item iii, specify how voluntary holdback is submitted, is it through the PIT or via file transfer? Does it have to be done through PIT or can it be a bilateral trade?

On page 6, specify that “Deficit” participants will notify PTO of amount of holdback needed.

On page 6, describe results that will be posted, will this include which participant(s) you will be paired with, or just volumetric data?

On page 6, specify that “Surplus” participants can exchange holdback. Text states that holdback exchange can occur between 07:00 and 12:00, but Figure 2 (and Design Document) indicates it can occur from 07:00 to T-120.

On page 5, is it “Preschedule” or “Prescheduling” Day? Should be consistent throughout.

Figure 2 is not referenced anywhere in the document.

1. 1. SCL generally supports the timeline of the preschedule day but feels there needs to be more flexibility for Participants to utilize the day-ahead market to address any potential deficits as calculated by the Sharing Calculation. The MIDC trading hub on ICE over the last five years continues to trade later and later. Between the time of 600am-630am, the ICE MIDC market and other trading locations may not be framed up (bid/offer) to provide Participants the opportunity to procure for a deficit.
   2. IS it possible for the WRAP program, during its non-binding nature, to assess if the 600am-630am timeline on the Preschedule Day is meeting the needs of the WRAP Participants to procure their deficit position, and if it isn’t meeting the WRAP Participant needs, it could be moved to a later time say between 630am-730am?
   3. Is there more to the last sentence in this?

SRP appreciates the efforts of the Western Power Pool, the WRAP operator (SPP), and the Operations Timeline taskforce to develop and put forth a timeline of the Operations Program. However, the last sentence or paragraph of this section appears to be missing. 

SRP is generally supportive of the timeline and it appears to be workable. However, SRP encourages the WPP to monitor how the timeline aligns participant’s trading hours and provide necessary flexibility on the preschedule days.