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- 'The Price for Energy Deployments is known as the Energy Declined Settlement Price.' - This should be in the definitions. For the first-time reader, this language is unintuitive.
- 1st paragraph, last sentence + 2nd paragraph - Seems to have some redundancy
Powerex suggests that the “Energy Declined Settlement Price” be renamed, to be more inclusive of its application to settle energy deployed quantities as well.
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“Holdback Requirement not deployed” could be replaced with “Unheld Energy and Energy Declined” for clarity.
Regarding pricing for voluntary holdback and energy deployment, should the tariff pricing apply to Make Whole Adjustments in addition to Holdback Requirements and Energy Deployments?
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This section could benefit from actual examples, so the verbiage is easier to follow and understand.
Energy Declined is confusing nomenclature; suggest using ‘Energy Deployment’ settlement price instead. It is unclear if the Make Whole Adjustment will be calculated on an hourly or daily basis.
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“Section 4.6 of this BPM shows how to allocate the Make Whole Adjustment when there is a single Participant with a Holdback Requirement that is being allocated to multiple deficit Participants. The Participant with the Holdback Requirement should receive a Make Whole Adjustment equal to their maximum total Holdback Requirement. The obligation for providing the Make Whole Adjustment can will/shall be shared among multiple Particpants.”