No response submitted.
The Introduction says “…Tariff directed transactions are known as Holdback Requirements (see BPM 204 Holdback Requirement) and Energy Deployments (see BPM 205 Energy Deployment).” – It would be helpful to add what the terms Holdback Requirement and Energy Deployment are at the end of the sentence, or in the Definitions. For example, “Holdback requirement is a MW quantity determined on a prescheduled day that a participant is required to be capable of converting into an Energy deployment on a given hour of the succeeding operating day.”
The Background section states “Prices and Final Settlement Revenue...will be made available to any Participant having a Holdback Requirement or Energy Delivery transaction. However, the following section says the Total Settlement Price will be publicly available, these sentences don’t fit together well for readers to understand. Is it public or only available to participants with a transaction?
1. BPA suggets WPP enable discussion on the fact that with WRAP implementation, a single tag cut could result in: 1) failure to deliver charges under WRAP; 2) LDs under WSPP; and 3) EIM imbalance charges (currently for participants). WSPP failure to deliver charges compound for 5 years as well. There is lot of accumulation that may need to consideration.
2. BPA suggests consideration of an addition of a section that identifes what is not in scope of the BPM (i.e. the program settlements between participants and WPP).
3. BPA would like to discuss the mechanics and possibly cover it in this BPM or in BPM 209 if necessary how those entities who participate in the CAISO WEIM, when a failure to deliver happens, is there a possibility that they would both pay the WRAP penalty and then also pay for the imbalance energy and additional subsequent CAISO settlements?
4. Paragraph 2: Propose removal or modification of "in line with current bilateral practices" as the transactions aren't really "in line" with bilateral practices and also "current" may be difficult to snap a chalk line and undersatnd what that intent is.
5. Paragraph 2: There have been discussions regarding if WRAP enabling agreements will be needed. BPA would like to discuss and potentially include in this BPM.
6. Missing a "the" in front of Tariff
No response submitted.