3. Notification of Anticipated Delivery Failure
4. Ensure the energy profile on the E-Tag for the intended delivery accurately reflects the expected non-delivery.
This will need to be completed by the deficit entity, as they’re the buyer, and the only ones able to change the E-Tag. Does the BPM need to clarify this point?
1. Notification of Anticipated Deliver Failure: This section does not include steps for recording the non-delivered amounts in After The Fact (Actual) data. Submission of After the Fact/Actual data that corresponds to a energy delivery and/or non-delivery from the program should be required by both parties.
2. E-Tags don’t hold non-delivery information, they hold delivery schedule. So the E-Tag should be updated to the correct 'delivery' schedule.
No response submitted.
In section 3, item 4 it instructs Participants that are expecting to fail on deliver of Holdback to adjust the tag. Since this section is written in a way that a Participant is anticipating not being able to deliver, would it be best to not adjust the tag until there has been confirmation that deliver failure will occur? Alternatively, we could change the perspective of the section from anticipation of non-delivery to actual non-delivery rather than anticipation of non-delivery.
No response submitted.
This section establishes that WRAP deliveries are essentially non-firm, and that the BPM does not specify any minimum notice time for an anticipated delivery failure.
PacifiCorp understands the program financially disincentivizes non-delivery, however, allowing Participants to choose to fail after the preschedule window is problematic for several reasons. PacifiCorp is of the opinion that Resource Adequacy obligations should be of the same priority as firm load.
First, allowing a Participant to opt-out of delivery after the preschedule window can cause significant reliability problems for receiving Participants, especially with no minimum notification time. This BPM enables a Participant to elect to not fulfill their WRAP obligations. Curtailing non-firm energy schedules is common in a Balancing Authority’s operating procedures for EEA mitigation and management. It would then be expected that reducing WRAP holdback delivery would occur as a common practice, no matter the financial disincentives, as it would be for reliability reasons.
Second, there needs to be a clear understanding of expectations for participants to follow. Language that uses “.. as soon as practicable” does not achieve that goal. With no minimum notice time, nothing prevents a Participant from curtailing deliveries intra-hour, after the WECC scheduling deadline, or after various hourly organized market checkouts (for example, T-40, T-55 and T-75 in the Western Energy Imbalance Market). Many Participants who participate in organized markets will not sell power even further in advance of the operating hour, making replacement power even less likely to be sourced.
Third, by establishing that WRAP deliveries are non-firm, this BPM prioritizes WRAP holdback delivery below potential contracts that do not even qualify as capacity in the forward showing, which PacifiCorp finds counterintuitive.
Additionally, section 4 requires a Participant anticipating Energy Delivery Failure to ensure the energy profile on the e-tag accurately reflects the expected non-delivery. Based upon common industry practice, it is the receiver of holdback who would have been responsible for prescheduling the e-tag, and therefore is the entity able to modify the energy schedule in real time. Due to this, the BPM does not address circumstances in which an entity neglects or refuses to reduce an energy schedule to reflect anticipated non-delivery.