Please see comments attached. 

Powerex believes the BPM would benefit from expanding the Definitions section 1.4 and listing all capitalized terms. This would provide participants with a useful reference for the energy components and prices used in the settlement process. 

PAC appreciates the opportunity to comment on this BPM.

For clarity, it would be helpful to qualify references to Participants as Surplus Participants or Deficient (Deficit) Participants throughout this BPM.

Inclusion of formulas wherever possible, such as in section 4.5, would be very helpful.

We would find examples of all calculations useful in being able to understand the BPM and the settlements process.

We would also appreciate a description of what is expected of participants if one or more components of the settlements prices are not available in a timely manner.

Overall, this document could benefit from labeling the Participant in the examples provided as either the Surplus or Deficit Participant.  

Question: Curious how the BPM might change with DA market implemenation? Is there an opportunity to change a BPM once its been approved by the board? 

Also, providing examples with screenshots from the WRAP OPS Client tool to articulate the many calculations listed in BPM 206 could aid in helping the reader visually understand the various calculations listed in the BPM. It would also provide clarity to the reader regardless of their level of understanding of the WRAP program. 

Seattle appreciates the opportunity to comment on BPM 206. Thank you! 

Shell Energy North America (US), L.P. (“Shell Energy”) appreciates the constructive conversations leading up to this business practice and thanks WPP for the opportunity to comment. 

Idaho Power has a couple of general comments on this BPM:  first, it is highly repetitive of the tariff.  There are several sections that appear to repeat the tariff word for word.  We suggest referring to the tariff where possible, rather than repeating it word for word, to avoid redundancy and the possibility of errors if one document is changed in the future and the other is not.

Second, the BPM is highly technical and can be difficult to follow.  Providing numerical examples of how the formulas would work, given specified assumptions, would help a lot.

Third, it would be extremely helpful if WPP could provide links to where the CAISO Hourly Day-Ahead SMEC and CAISO Average Day-Ahead SMEC are located so that participants can validate the prices used in the settlement calculations.

Finally, is the CAISO Average Day-Ahead SMEC a price that is caculated and provided/published by CAISO or is it something WPP will be calculating?  If the latter, how will it be calculated?  This should be described in the BPM.

Idaho Power very much appreciates WPP's work on this BPM and the opportunity to comment. Thank you.

APS would like to request a structured test scenario involving holdback and energy deployment to assist settlements personnel in implementing validations for WRAP transactions.

Comments from previous BPM 206 that may be relevant to BPM 207:

Will WPP establish standard settlement terms between participants?

Is there guidance on how disputes will be handled in case a participant does not agree with any of the settlement calculations?

How will the quantities and values be provided to the Settlements team? We would prefer an SFTP site. (The Total Settlement Price; The Holdback Settlement Price; The Energy Declined Settlement Price; Any Make Whole Payments; and The total settlement amount owed.)

How will the transaction data be provided to the PO?

Receiving the pricing data 10 after receipt of transaction data from participants is long (7 BD after operating day +3 BD after receipt of data) – could run into issues with Settlements close process if event occurs at end of the month.