Shell Energy North America (US), L.P. ("Shell Energy") appreciates the opportunity to comment. As one of only two non-utility entities serving load in the WRAP region, maintaining confidentiality regarding Shell Energy’s load, resources, contracting practices, prices, load forecasting and position is key, as these constitute trade secrets. As such, Shell Energy believes, as a threshold matter, data submitted to WPP or SPP should be treated confidentially by presumption. That is, there should not be an explicit requirement to mark data as confidential to remain so.
Shell Energy understands there will be cases where information is disclosed to FERC, regulators, or other venues as courts. In these cases, it is reasonable to ask for sufficient notice be sent to the WRAP participant. In addition, should WPP possess confidential WRAP participant data that is subject to disclosure, WPP should endeavor to transmit the data in a confidential manner to the regulator requesting or subpoenaing it. In doing so, WPP must make the confidential nature of the data explicitly known as WPP is obligated to keep certain information confidential pursuant to the WRAPA.
Finally, any aggregation should be at a “high enough” level such that it is not possible to back into participant specifics based upon only lightly aggregated data. As an example, if only a single WRAP participant has a biomass generator, WPP should not disclose there is a biomass generator on outage; instead, this disclosure should be aggregated as a ‘thermal resource on outage’ to sufficiently aggregate and protect the confidential nature of a resource on outage.
No response submitted.
No response submitted.
SRP is encouraged by the WPP’s ongoing efforts in the developing of WRAP BPMs and has provided comments on relevant sections within this BPM.
Further, SRP requests the WPP establish a standardized receipt of acknowledgement process to be uniformly applied across all relevant sections of BPM 402. The process should mandate that the WPP acknowledges receipt of any documents or communications from participants within a specified timeframe, detailing the content received and the date of the receipt. This acknowledgement should be in a form that is verifiable and can be archived and referenced.