In the Introduction, BPM 202 Participant Sharing Calculation Inputs, needs changed to BPM 203 Participant Sharing Calculation Inputs.

Tacoma Power recommends that the Program Operator consider implementing a procedure to inform participants when the Uncertainty Factor is reduced or increased from the current value displayed in the Program Interface Tool.

Tacoma Power also recommends that the Program Operator consider implementing a process under which participants may programmatically access the Uncertainty Factor for planning and shadow sharing result calculations, if that process is not already contemplated in another BPM.

No additional comments

PacifiCorp does not support the concept of reducing the Uncertainty Factor in the preschedule timeframe. The WRAP tariff does not oblige WPP to implement this practice. Reducing the Uncertainty Factor, thereby increasing a Participant's exposure to Holdback obligations, risks putting a Participant in a position of insufficient operating reserves on the operating day. 

BPM 209 - Energy Delivery Failure Charge creates a provision that a non-delivery waiver can be granted to a Participant if the Participant can prove it needed more Uncertainty MW's than calculated in the preschedule WRAP Sharing Calculation. When the Uncertainty Factor is reduced because a WRAP subregion as a whole is short, a regional stress event (heat wave, cold snap) is likely to be taking place. Participants assigned a Holdback obligation in these instances are far less likely to deliver. PacifiCorp is concerned Participants will begin to question the reliability of the WRAP holdback product should non-delivery become a repeat occurrence.