Powerex suggests that Section 3 be revisited because there is significant onus placed on Participants to designate and label each individual document and data set, that contains confidential or commercially sensitive information, prior to submission.  Section 3 also does not identify how data submitted through Application Programming Interfaces (API) would be designated as confidential or commercially sensitive information.  The process outlined causes additional administrative burden, whereas a more simplified approach would be beneficial for WPP and Participants. 

Powerex suggests that entities could provide a letter that covers all submissions to the WRAP and would treat all documents and data as confidential instead of an individual labelling exercise.   This suggested approach would align with WRAP Tariff Section 10 and reduce administrative burden on Participants and WPP.

All forecasted Electronic data submitted as part of the OPS program, should be considered sensitive and confidential until it becomes After the Fact, and then the marking they indicate would apply. That means that all multi-day and operating day data is confidential until we pass the specific operating hour.

In the phrase “should be cleared marked,” SRP suggests correcting “cleared” to “clearly.”

Correction: “the confidential or commercially sensitive information included on each page should be clearly marked.”