SRP request clarification on the process for tagging energy confirmed in the day-ahead environment. If energy can be confirmed/declined up to 85 minutes ahead of the operating hour and tagged within 60 minutes ahead of the operating hour, it is unclear how energy “confirmed” in the day-ahead environment should be tagged within standard pre-schedule timeframes.

There seem to be several problems with this requirement:

1. Usually for transmission owner tags: the seller is responsible for transmission from resource to Mid C and the buyer is responsible for transmission from Mid C to load.  The deficient party is not the transmission owner responsible for tagging delivery for all legs.

2. For multiple legs of transmission:  Suggest that the BPM be silent on who tags and let the transaction parties determine it, but still require tagging by T-60.  

If the seller (supplying participant) tags energy to mid-c delivery point, but receiving party fails to tag, deliver from mid-c to load, correct actions have been taken on the part of the delivering participant.

Delivery at any other point would be completed through the bilateral agreement of a different delivery point, and the respective transmission owners would be responsible for tagging that delivery

APS has the understanding that an e-tag can only be adjusted by the author of the e-tag which is authored by the deficient entity according to this section, however the responsibility to take action on the e-tag is placed on the surplus Participant. Depending on what action is expected the surplus entity may not be able to, for example if the holdback was requested to be deployed the surplus entity could not adjust the e-tag created by the deficit entity.  APS requests clarification on the expectation to take action of the surplus entity in this regards.

The first sentence of p5 regarding the E-tag for the Energy Deployment is somewhat unclear. Instead it could be rewritten as follows - 

" In any Subregion with a Central Hub, the E-tag will reflect a path that has generation sources at the surplus Participant, goes through the hub, and is delivered at the load of the deficient Participant."

PacifiCorp would prefer a policy which requires Participants who have confirmed a need for Holdback to submit e-tags for the full requested Holdback amount on the Preschedule Day. If the Participant later has a reduced (or no) need for Holdback, any tag adjustments will result in a surplus for the providing Participant(s).

If Holdback is left untagged until T-60, there may be unforeseen consequences for the providing Participant, with limited (or no) time to cure. Organized market tests run before the T-60 timeframe, and altering a Participant’s interchange value while hourly market tests are still running may have negative impacts on the providing Participant.

Tacoma notes the timeline from T-85 to T-60 for the creation, or even adjustment, of tags between deficit and surplus participants is very limited and may result in missed deadlines and incorrect tags.

Since both participants will need to reserve enough transmission to possibly deliver/receive the maximum about of the Holdback Capacity assigned during Preschedule until the T-85 deadline anyway, Tacoma suggests tags be created on the Preschedule Day whenever possible.