01: Please supply any comments related to the Introduction, Definitions, or Background sections.
No response submitted.
02: Please supply any comments related to the Notification of Anticipated Delivery Failure section (3) .
No response submitted.
03: Please supply any comments related to the Calculation of Delivery Failure Charge section (4).
No response submitted.
04: Please supply any comments related to the Dollar Limit on Delivery Failure Charges During a Forward Showing Year section (5).
No response submitted.
05: Please supply any comments related to the Allocation of Revenues from Payment of Delivery Failure Charges section (6).
No response submitted.
06: Please supply any comments related to the Waiver of an Energy Deployment Obligation section (7).
It is important to note that, since the Program Sharing Requirements are determined on a preschedule basis, the forecasted information provided by the participants will always contain some uncertainty, and at times that uncertainty may be significant. For example, to accommodate a holiday occurring on or near a weekend, the Preschedule Day for a given WRAP Operating Day may be several days in advance of that Operating Day, and as such the uncertainty in the forecasts of load, VER output etc. could be significant, and unavoidable. Powerex would recommend adding the following to the examples of possible valid justifications in Section 7.2:
“4. A Participant’s actual load and resource value(s) deviating from the forecasts provided for the Operations Program Sharing Calculation Inputs. For example, it would be appropriate to grant a Waiver to a Participant if the Participant was unable to provide holdback because that Participant’s actual load at the time of the failure was higher than the load forecast they provided for the Sharing Calculation, and it can be demonstrated that the forecast provided was reasonable and accurate based on the information known at the time the information was prepared. “
“5. It can be that demonstrated that the Uncertainty Factor determined by the Program Operator and used in the Sharing Requirement Calculation for the period of the Delivery Failure (as outlined in BPM 203) was insufficient to cover a reasonable level of uncertainty faced by the Participant and resulted in variances between forecast values submitted on the Preschedule Day, and the actual values experienced during the period of the Failure in the Operating Day.”
Also, it should be expected that any review of an Energy Delivery Failure Charge would include a review of the Sharing Requirement Calculation that set the failing Participant's requirement during the period that the failure occurred. When performing that review, the Program Administrator may require additional information from all Participants that provided data into the Sharing Requirement Calculation during that period. Powerex recommends that the following language, or something similar, be added to section 7.2:
“When reviewing Waiver requests, in order to validate the Sharing Requirement calculation associated with the period of the failure, the PA may request additional information associated with the Sharing Requirement Inputs from all Participants during the period the Delivery failure occurred.”
07: Please supply any comments related to the Possible Expulsion for Repeated Energy Delivery Failures section (8).
No response submitted.
General Comment