PacifiCorp is uncomfortable with the outcome for Participants who are expecting to receive Holdback from another Participant, but do not receive it due to a waived non-delivery event.

If the non-delivering Participant receives a waiver, the original intended recipient of the holdback receives nothing – neither MW’s nor financial compensation. This outcome is less desirable than WSPP Schedule C, where liquidated damages are paid in the event of non-delivery. PacifiCorp would suggest the Participant who experienced non delivery receive some amount of compensation, such as 2X  the applicable hourly index for the volume of energy not received.

City Light has no additional comments on this BPM.