• 'Unheld Energy' - New term, need defined
• 1st pragraph, last sentence - Does this mean that the Participant who was deficit has to pay based on the price index to which the holdback or Energy Deployment was delivered?  It would seem that would need to be the case in order to make sure that there is enough revenue to pay both the Participant who is supplying the energy/holdback and the Participant who provided the transmission.  Another simple way to deal with this is to say that the receiving party pays the sum of these two.
• Same area as above - To compute this transmission payment the BMP needs to clearly specify if this difference is computed as source minus sink or sink minus source.

Where seller and buyer are located in different subregions, the wording could be more clear to state the highest of the subregions' indices will be applicable to calculated settlements. 

No comment.

Program Administrator and Program Operator Roles: The PA will be responsible for calculating and posting settlement quantities and prices in accordance with the WRAP Tariff. 

Is this information available for everyone to see, or only those associated with your transactions? 

Transaction Components Provided: 

Specifically, the PA will calculate and provide to each selling and purchasing Participant in the Holdback Requirement or Energy Deployment transaction with the following quantities and values, as applicable to each of the two types of transactions: How would disputes be addressed when it is applicable?  

Timing 

Will Participants have to agree on the transaction data before submitting it to the PA? How will transactions be recorded? 

It is unclear from section 4.8 if the intention for surplus participant A providing energy deployment and transmission (same participant) to deficient participant B be compensated the applicable index price for both the energy component and transmission or if the applicable index would be compensation for only the transmission component.   Please include example calculations.    

Will energy be deployed locally versus crossing regions in order to minimize transmission costs?

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