Avista believes the Make Whole Adjustment should include a mechanism compensating the seller for all incremental Washington CCA obligation incurred during energy deployments.
- Is this computed on an hourly basis or is it only applicable for certain fixed blocks of time (such as heavy load hours as defined by WECC)? The concept of Capacity Critical hours should be in this BP.
- 'Make Whole Adjustment (when applicable) = How is 'when possible' defined? Is it ‘automatically’ tracked or does the selling entity need to take action? Need to explain when it is applicable.
- Real-time Value of Unheld Energy = (Maximum Holdback MW in Block – Holdback MW Requested) × Real-Time Applicable Index Price - Clarify if 'Block' refers to the time blocki in question.
- 'Possible Block Sale Revenue' -
- Wording conveys uncertainty. Should this be described as “Allowed” or…??
- How is this going to be computed and who is going to make this calculation?
- Maybe opp cost of basic DA sale? Consideration for geographic price basis opp cost? Eg, did BPA give up a COB or NOB sale but was compensated at a lower MidC price?
- 'Final Settlement Revenue' - New term?
- 'Unheld Energy' - This is a new term? Need definitions
Powerex agrees with the settlement mechanism proposed in the BPM to allocate Make Whole to multiple buyers. We believe that an example with sample prices and energy volumes would help participants understand how the cost is allocated across multiple buyers. To keep the section clear and succinct, this example could be in an appendix at the end of the BPM. The existing language in this section can be rewritten to be clearer on how the settlement is implemented, while referencing the appendix for the example calculation.
No response submitted.
'Unheld Energy' is not defined in this document, the WRAP design document or the WRAP tariff.
Non-dispatched energy is an undefined term, replace with “Unheld Energy and Energy Declined”.
Possible Block Sale Revenue is undefined, include a definition and formula.
As mentioned in Comment 7, Final Settlement Revenue is undefined, include a definition and formula in Section 4.4.
We will raise this comment again, the price for Real-Time Value of Energy Declined should be the Real-Time index price, as this represents the seller’s opportunity cost.
The Make Whole Adjustment cannot be less than zero.
No response submitted.
No response submitted.
This section could benefit from some examples of what this would look like.
The Washington CCA program applies carbon compliance costs for carbon emissions associated with, among other things, electricity imported or generated in Washington State. The Make Whole Adjustment should include a provision for surplus WRAP participants to recover direct carbon compliance costs associated with energy deployments to deficient entities inside Washington State. Shell Energy believes all WRAP energy deliveries would be treated as ‘unspecified imports’ under the Washington CCA, because the purchaser would not have a preexisting contract for specified or non-emitting deliveries of energy deployments. This is an issue which requires additional stakeholder discussion, and the BPM should speak to the process if another state in the WRAP footprint implements a carbon pricing scheme.
No response submitted.
No comments in this section