SRP suggests that BPM 204 explicitly reference any requirements related to bilateral transfers to ensure firm generation (G-F, WSPP Schedule C, etc.) or transmission (7-F, 7-FN, etc.).

The first sentence should be amended to be “Participant (A) may agree with any other surplus Participant (B)”.

In the example provided in Sec. 7 , would Participant B assume liability for potential energy non delivery charges if they were transferred ownership of the Holdback Requirement for Participant A?  Please provide clarification 

Please detail what, if any feasibility check is performed by the PIT when a bilateral transfer of Holdback occurs.

Due to industry convention and WRAP requirements, it will be the receiving Participant who ends up needing to re-tag the Holdback delivery if a bilateral transfer occurs. Please elaborate on what recourse a receiving Participant has if a failure occurs, or if the transfer is infeasible for the receiving Participant.

In particular, transmission availability changes from Preschedule Day to Operating Day. If Participant A is scheduled to receive Holdback from Participant B, and Participant B transfers its Holdback obligation to Participant C, but Participant A does not have sufficient inbound transmission available from Participant C, what is the outcome? Please cover this and other avenues of recourse Participant A would have if there is a failure or error between Participant B and Participant C.

“Requirement transfer shall be a bilateral arrangement settled outside the WRAP, provided, however, that both Participants of such Holdback Requirement transfer must notify the Program Administrator and the Program Operator in a timely manner using the PIT between 07:00 PPT and T-120 on the Operating Day.”

Tacoma would like to clarify that the timeline to notify the PA and PO would be from 07:00 PPT on the Preschedule Day to T-120 on the Operating Day (unless this interpretation is incorrect).