Powerex understands from Section 15.1.1 of the WRAP Tariff that during Non-Binding Seasons participants will not be subject to Holdback Requirements. Powerex suggests that the following language (or language similar) be added to Table 1, Tier Three (Non-Binding Participants), Column 3 (Obligations to WRAP) or be indicated as a footnote to Table 1:
“Not subject to binding WRAP obligations for Operations, including the Holdback Requirement.”
"Voluntary Holdback based on the Priority Tiers of the Participants needing assistance in any case where the needed assistance is less than the available voluntary assistance. "
It really doesn’t matter if it is voluntary offered or positive sharing holdback - assistance is granted on a single set of Priority Tiers.
Consider rewriting the sections to describe access to 'Holdback' any and all that is available as a single pool, that gets allocated by Priority Tier.
It really doesn’t matter if it is voluntary offered or positive sharing holdback - assistance is granted on a single set of Priority Tiers.
Consider rewriting the sections to describe access to 'Holdback' any and all that is available as a single pool, that gets allocated by Priority Tier.
Is there a priority in which surplus supply will be allocated between using voluntary and calculated surplus? It is unclear in the BPM if the deficit entities will first be allocated calculated surplus, and then voluntary surplus based on their priority tier, or will all supply be allocated as one bucket?
Section 4 of BPM 210 does not specify how a participant who had Monthly Capacity Deficiency yet did not pay Forward Showing Deficiency charges as result of using the ETD or No-JCAF option would be placed into a priority tier. As a comparison BPM 109 provides specific guidance for this scenario so it would helpful to do the same in BPM 210.
-PAC would appreciate a statement explicitly stating Tier 3 recipients of holdback are financially obligated for that energy. Non-binding participants are shielded from FS Deficiency Charges and Delivery Failure charges, but if MWs are received through the program, participants are obliged to pay, regardless of binding status.
-Will each participants' tier be public information? Or will each participant be informed only of their own tier?