1.  The closing paragraph suggests repeat offenders are limited in their penalties.  An example would give this better context for the BPM.  Also note the typo for "increased"

SRP recommends the WPP provide examples illustrating the calculation of the cap on Delivery Failure Charges. Clear examples would help stakeholders comprehend how this cap operates in practice, especially when compared to anticipated charges in forward planning periods.

Additionally, SRP requests clarification on whether there's a definitive limit to Delivery Failure Charges. This may help participants' financial planning and risk management strategies.

No comments at this time.

Can this Participant Dollar Limit be simplified to sum the equivalent FS monthly deficiency charge for the largest (MW) Energy Delivery Failure for each month in the FS Year thus far? 

Why is the 1st bullet point split out? 

Would be great to walk through an example as the methodology seems convoluted. 

Energy Delivery Failure clarification: WPP should clarify if the index multiplier is or is not able to exceed the FERC hard cap for energy which is currently $2000/MWh for the Western Interconnection.  Shell Energy suggests any delivery failure be subject to FERC’s hard cap.  Stated another way, regardless of the penalty multiplier, any total penalty collected should not to exceed FERC’s hard energy price cap in place when an energy delivery failure is incurred.  Without clarification, penalties would likely be found unjust and unreasonable by FERC.