The purpose of RA Transfer was to allow the transfer of RA Forward Showing Capacity Requirement between Participants. Powerex notes that the proposed edits to this section are attempting to address an inconsistency in the original tariff language. However, the proposed edits have the effect of describing an RA Transfer as a transfer of QCC, rather than a transfer of the Forward Showing RA obligation. Powerex suggest the proposed edits be replaced with the following language:
“16.2.7 Total RA Transfer: A Participant may agree with another Participant on a transfer of a portion of their FS Capacity Requirement (“RA Transfer”), provided that the details and duration of such transfer are reported to WPP for validation in accordance with procedures and information requirements specified in the Business Practice Manuals. Where such transfers have been duly reported and validated, an RA Transfer will be added to SUBTRACTED FROM the purchasing Participant’s Portfolio QCC FORWARD SHOWING CAPACITY REQUIREMENT and subtracted from ADDED TO the selling Participant’s Portfolio QCC FORWARD SHOWING CAPACITY REQUIREMENT.”
Powerex further notes that the implementation of RA Transfer may require a review and modification of the Operations Program Sharing Calculation and associated processes.
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