City Light suggest that use of an alternative Applicable Index Price or Hourly Shaping Factor, when necessary, should not require changing BPM 206 Settlement Pricing.  BPM 206 should contain language facilitating this possibility.

1.   Modify language to reflect:  If the Applicable Index Price data and/or Hourly Shaping Factor data necessary to calculate settlement for a month (in which there is a Holdback Requirement or Energy Deployment) is not available 60 days after the last day of the settlement month...

2.  Are the Applicable Index Price data and/or Hourly Shaping Factor data the only inputs that might be unavailable?

3.  BPA is somewhat uncomfortable with leaving it to the future to determine how to handle the use of alternative price indexes.  Once the program is live, changing BPMs is not a rapid process.  BPA suggests this be explored before binding seasons and the BPM 206 updated as necessary to better reflect a reliable protocol.

It is unclear in this section if alternative data would be utilized when the Applicable Index Price or the Hourly Shaping Factor is not available, since it is noted a BPM 206 change would be required, which needs Board approval. Is the PA going to use alternative data, or should WRAP Participants seek to agree amongst each other the terms of the transaction?06: Please supply any comments related to the Timeline - Changes to Inputs after Settlement Values have been Calculated section (5.2).

This section notes a notice of re-calculation will be sent to all Participants; however, it doesn’t expand if those Participants may appeal the re-calculated settlement? Would the re-calculation trigger an additional 90-day dispute period?

SRP requests clarity regarding any authority of the Program Administrator to utilize alternative data in the event of unavailable data.  For example, is a BPM 206 change required when the Program Administrator’s data source has missing data for one interval? 

SRP requests clarity on whether the Program Administrator assessment would ever determine that alternate data should not be utilized in the event of unavailable data, including examples of how calculations would proceed if the Program Administrator assessment does not determine that alternate data should be utilized while external Input Data is unavailable.