07 Please supply any comments related to the Settlement Pricing Overview and Components - Application of Pricing and Quantities for Holdback Requirements and Energy Deployment Transactions section.




July 27, 2023, 2:09 p.m.
LORI HERMANSON | Avista
No response submitted.

July 31, 2023, 2:37 p.m.
KATIE NELSON | BPA

2nd paragraph, 'Negative Sharing Requirement' - What does this mean “negative” sharing requirement Should be defined above?  It’s difficult to understand the rest of this paragraph without more context.
This should be in definitions. 


Aug. 1, 2023, 2:27 p.m.
RAJ HUNDAL | PWX
No response submitted.

Aug. 2, 2023, 2:07 p.m.
JOHN MAYHEW | Public Se…

I’m trying to decipher and breakdown the following paragraph from page 6, of BPM 206

Application of Pricing and Quantities to Determine Amounts Paid by Buyers and Amounts Received by Sellers for Holdback Requirements and Energy Deployments

A Participant assigned a Holdback Requirement on a Preschedule Day for any hour of an Operating Day shall be paid the Holdback Settlement Price times the MW quantity of the Holdback Requirement. A Participant that provides energy to another Participant pursuant to an Energy Deployment shall be paid the Energy Declined Settlement Price times the MWhs of energy provided to such other Participant, and its total payments shall be reduced by the Energy Declined Settlement Price times the MWhs of energy that would have been provided under a Holdback Requirement but were declined by the other Participant. A Participant assigned a Holdback Requirement also shall be paid, when applicable, a Make Whole Adjustment.

As I understand it, the following would be the settlement:

Participant A:  Holdback of 100mw (+100)

Participant B:  Deficit of 100mw (-100)

Participant B Opt-in to receive 50mw

 

Participant A receives:

  1. Holdback Settlement Price (Total Settlement Price minus Energy Declined Settlement Price) x 100 (for total holdback)

(+) PLUS

  1. Energy Declined Settlement price (lesser of 0.80 times Total Settlement Price, or Real-Time Applicable Index Price for the hour) x 50 (for delivered MW)

(-) MINUS

  1. Energy Declined Settlement price (lesser of 0.80 times Total Settlement Price, or Real-Time Applicable Index Price for the hour) x 50 (for energy not opt-in)

Therefore, items 2 and 3 above cancel each other out, correct?

Participant B pays:

  1. Holdback Settlement Price (Total Settlement Price minus Energy Declined Settlement Price) x 100 (for total holdback)

(+) PLUS

  1. Energy Declined Settlement price (lesser of 0.80 times Total Settlement Price, or Real-Time Applicable Index Price for the hour) x 50 (for delivered MW)

(-) MINUS

  1. Energy Declined Settlement price (lesser of 0.80 times Total Settlement Price, or Real-Time Applicable Index Price for the hour) x 50 (for energy not opt-in)
  2. Contribution to the payment of Make Whole Adjustment, based on its negative Sharing Calculation.

Why aren’t there two separate calculated prices for:

Energy Declined Settlement Price (for holdback energy not opt-in)

Energy Deployment Price (for holdback energy opt-in & delivered)

In the scenario above, because 50% of the holdback was opt-in, the delivered and declined energy offset.  Participant A is only receiving Holdback Settlement and potential Make Whole Adjustment.  Is that the intention here?


Aug. 3, 2023, 7:43 a.m.
BENJAMIN FAULKINBERRY | PacifiCor…

An example would be appreciated in this section, as is provided in section 4.6.


Aug. 3, 2023, 12:09 p.m.
SANDEAP REDDY | Puget Sou…

Final Settlement Revenue (FSR) should be defined as including Holdback Settlement and Energy Deployment Settlement.  FSR should be described in a formula as well as in the text.

There are references in this section to a reduction in payments to Surplus Participants and a credit to Deficient Participants based on the Energy Declined Settlement price multiplied by the MWh of energy declined.  Including mention of this credit in section 4.4 implies that this component should be included in FSR, which also includes Holdback Requirement payments and Energy Deployment payments.  This credit is also included in section 4.5 (Make Whole Adjustment or MWA) as the Real-time Value of Energy Declined.  If this wording was intentional, the credits in the FSR and MWA cancel each other out, artificially reducing the FSR and increasing the MWA to offset.

This language is unclear, “A Participant that had a negative Sharing Requirement for any hour of an Operating Day, which was incorporated in the calculation of Holdback Requirements of any Participants for such hour, determined as of the Preschedule Day”.  Although this has been copied from the tariff, specifying that that the Deficient Participant reserved the Holdback during the Preschedule opt-in process might offer more clarity.

In the section describing which payments a Deficient Participant is responsible for, it includes Holdback Settlement, Make Whole Adjustment, and a credit for Energy Declined (which, as mentioned above, is problematic).  It omits any reference to payment for Energy Deployed.


Aug. 4, 2023, 7:26 a.m.
LEAH MARQUEZ-GLYNN | Tacoma Po…
No response submitted.

Aug. 4, 2023, 1:12 p.m.
LINDSEY SCHLEKEWAY | NVE

This section indicates that a participant would pay a holdback for any instance that the participant was calculated to be in deficit by the surplus calculation. NV Energy does not believe this is the intent of the program and offers the following revision for consideration in the Business Practice.

“A Participant that had a negative Sharing Requirement and elected to receive holdback for any hour of an Operating Day, which was incorporated in the calculation of Holdback Requirements of any Participants for such hour, determined as of the Preschedule Day, shall pay the Holdback Settlement Price times the MW quantity of such negative Sharing Requirement.”


Aug. 4, 2023, 1:14 p.m.
MARA KONTOS | Seattle C…

Question/Comment: “A Participant that provides energy to another Participant pursuant to an Energy Deployment shall be paid the Energy Declined Settlement Price times the MWhs of energy provided to such other Participant, and its total payments shall be reduced by the Energy Declined Settlement Price times the MWhs of energy that would have been provided under a Holdback Requirement but were declined by the other Participant.”  

Is this saying that a Participant isn’t paid for an energy deployment if the deployment is declined? Please clarify.  

This is quite hard to understand. This verbiage could benefit from an example of the calculation 

Also, “A Participant that declines energy that would have been provided under a Holdback Requirement shall be credited the Energy Declined Settlement Price times the MWhs of energy declined by such Participant. 

Does this mean that the Participant is charged for the deployment? It isn't easy to understand the way it’s written. How can they be credited an amount if they weren’t charged for it? This could benefit from an example and the Surplus Participant and Deficit Participant clearly labeled throughout the BPM. 


Aug. 4, 2023, 2:02 p.m.
IAN WHITE | SE

This section is generally hard to follow as it relates to the payment for energy deployments and the energy declined settlement price, please include examples.


Aug. 4, 2023, 3:25 p.m.
CAMILLE CHRISTEN | Idaho Pow…
No response submitted.

Aug. 4, 2023, 3:35 p.m.
TYLER MOORE | Arizona P…

“A Participant that provides energy to another Participant” – unclear if there is a 3rd participant or only 2 with the wording provided.

“negative Sharing Requirement/Calculation” – does the negative requirement mean the participant needed to be a recipient for holdback/delivery?