NV Energy appreciates the opportunity comment and offers the following comments for the Western Power Pool’s consideration. NV Energy believes it would be helpful to understand the reasoning behind the 10% adder that is included in the total settlement price. The settlement calculation incorporates a make whole payment if the participant that supplied the holdback did not receive enough revenue to recover the cost for selling the energy in the market.  Therefore, it is unclear why an additional 10% is necessary as an adder for the total settlement price.

• Introduction, 1 paragraph, last sentence: May want to add a sentence stating something like: The program fully expects to revise this BP in coordination with the emergence of organized markets affecting its members. Also to that point: Probably a good idea to keep this BP as a draft until organized markets settlement structures are finalized. 
• Definitions:
  • DA Applicable Index Price: DA ICE index likely to become even more illiquid with emergence of organized DA markets.   Will likely need to change this Index
  • Holdback Settlement Price: It’s not obvious how the daily index figures into these statements since the Declined Settlement Price uses the RT index.
  • Energy Declined Settlement Price: Terminology creates confusion.  If deployed/undeployed energy terms are used in the settlement calculation, and they are assigned the same price, maybe state these are priced the same to avoid confusion. It’s difficult to understand this statement of value without understanding the definitions above.  For example, why “lessor”?  If RT is multiple times the price of DA, why would I want to be limited in my compensation for energy deployment?  I’m probably not understanding the logic here.
• Background, 1st paragraph, 2nd sentence: It might be helpful to identify the parties as “Participant 1” and “Participant 2” so it is easier for the reader to keep track of who is doing what.

Unheld Energy and Declined Energy are undefined in this document, and definitions are not included in the Design Document or the Tariff. 

In section 1, it states “… WRAP allows a Participant facing a calculated resource deficiency …  to require Participants with surplus resources to sell …”.  It seems that the Tariff/program requires this action, not the Deficient Participants.

In the definition of “Hourly Shaping Factor”, the term “relevant season” needs some clarity around the specific dates of the Winter and Summer season. 

With the pricing being dictated by the WRAP Tariff and calculated by the Program Administrator, what happens if pricing is delayed due to the availability of the published index prices? How will entities deal with credit exposures? 

“The WRAP Tariff thus provides for calculation of separate prices to compensate for Holdback Requirement and Energy Deployment, along with separate calculations of i) the amount to be paid and received as compensation for Holdback Requirement; and ii) the amount to be paid and received as compensation for Energy Deployment.” 

Would it be possible for an entity to be compensated for both the Holdback and Energy Deployment or just one or the other? 

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. 

As a general matter, the document should include definitions of concepts and terms used, such as ‘unheld energy’ included in an appendix to the BPM thus avoiding the hassle of referencing the tariff.  In addition, providing multiple examples of settlement calculations under different scenarios/pricing would avoid ambiguity. 

No comments in this section