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PacifiCorp notes this proposal will require a separate “checkout” function for WRAP deliveries to both ensure Participants agree with any charges for failure to deliver, and that Participants are appropriately compensated via the allocation process in Section 6, which could be protracted as there is the possibility of multiple failures to deliver the same amount of energy, as the required amount fails from the initial deliverer, who may or may not have a waiver, and moves to a second deliverer that who may also fail and request a waiver.
Allocation of revenues from payment of delivery failure charges: Penalties associated with a delivery failure charges where the failure was fully covered by another entity or entities should not be used to offset WRAP program costs. In doing so, the entity failing to deliver would still receive an indirect benefit through marginally lower WRAP program costs. Shell Energy recommends any uplift in this case should be allocated proportionally to the entity/entities which covered the deficiency. This is reasonable as it follows cost-causation principles.