Powerex notes that there may be circumstances in which a Participant may have a negative Sharing Calculation result but may still be able to provide Voluntary Holdback from resources surplus to their Forward Showing requirement. As such, Voluntary Holdback offers from a Participant with a negative Sharing Calculation result should still be utilized, unless that same Participant has confirmed a need for any amount of Holdback Capacity (i.e. that Participant has Opted-In). If the Participant does not elect to opt-in to take holdback, the Participant’s voluntary Holdback offers should stand.

Voluntary Offers should not be limited to ‘only’ when a participant has a positive sharing calculation.  A participant could have resources surplus to WRAP FS Capacity Requirements, but have a negative sharing calculation due to experiencing an extreme load day.  In this scenario, a participant would still have non-program surplus capacity/energy available due to a large portfolio surplus (above and beyond FS Capacity Requirement). A participant in this situation should be free to submit any and all surplus generation (above and beyond program capacity) as Voluntary Offers.

The first sentence in this section could be interpreted as to preclude the ability to offer voluntary assistance if you are obligated to provide holdback, but they may have additional above their obligation they would like to make on a voluntary basis but wouldn’t be able to based off the first sentence that reads, “Participants with excess supply that are not obligated to the WRAP through their positive Sharing Calculation result may voluntarily offer such supply to the WRAP as Voluntary Holdback.”

Section 5 does not clearly state what excess supply is not obligated to the WRAP.  Therefore, NV Energy proposes that WPP add a formal definition for voluntary offers or add in additional detail that clearly demonstrates what capacity is considered excess supply that may be offered into the program as a voluntary offer. 

As a point of clarification does  " excess supply not obligated to WRAP through their sharing calculation"  refer to capacity from resources not claimed for QCC in the FS Program?

It would be helpful to specify the time in which VH submission is required by

Is the Input Data File Specification intended to be a public or confidential document? Please provide a link or further direction on where to locate this resource on WPP’s website. PacifiCorp recommends WPP create a central repository for WRAP related forms and resources referenced in BPMs.

What purpose does submitting Voluntary Holdback ahead of the preschedule day serve? In mentioning this, the BPM should clarify if Participants who expect to be deficient can claim or call upon Voluntary Holdback beyond the Preschedule Day. If Participants can only confirm a need for Holdback on the Preschedule Day, despite Voluntary Holdback being offered further out in time, that should be restated here.

“Additionally, if a Participant offered Voluntary Holdback ahead of the Preschedule Day and then was determined to be deficient on the Preschedule Day by the Sharing Calculation results, the Voluntary Holdback that was previously submitted would not be utilized in the Operations Program.”

Tacoma would like to note the possibility a Participant would be able to offer additional resources to the WRAP via Voluntary Holdback even when their Sharing Calculation result indicates them as deficit (unless that Participant actively chooses to Opt-In for capacity).

This could be especially important during a widespread regional deficit.