01: Please supply any comments related to the Introduction, Definitions, or Background sections.

This BPM does not address the mechanism by which a delivery failure becomes either covered or non-covered. Unless this will be discussed in a future BPM, please elaborate on how an anticipated delivery failure will be solicited to other Participants to provide coverage of said failure.

02: Please supply any comments related to the Notification of Anticipated Delivery Failure section (3) .

This section establishes that WRAP deliveries are essentially non-firm, and that the BPM does not specify any minimum notice time for an anticipated delivery failure.

PacifiCorp understands the program financially disincentivizes non-delivery, however, allowing Participants to choose to fail after the preschedule window is problematic for several reasons. PacifiCorp is of the opinion that Resource Adequacy obligations should be of the same priority as firm load.

First, allowing a Participant to opt-out of delivery after the preschedule window can cause significant reliability problems for receiving Participants, especially with no minimum notification time. This BPM enables a Participant to elect to not fulfill their WRAP obligations. Curtailing non-firm energy schedules is common in a Balancing Authority’s operating procedures for EEA mitigation and management. It would then be expected that reducing WRAP holdback delivery would occur as a common practice, no matter the financial disincentives, as it would be for reliability reasons.

Second, there needs to be a clear understanding of expectations for participants to follow. Language that uses “.. as soon as practicable” does not achieve that goal. With no minimum notice time, nothing prevents a Participant from curtailing deliveries intra-hour, after the WECC scheduling deadline, or after various hourly organized market checkouts (for example, T-40, T-55 and T-75 in the Western Energy Imbalance Market). Many Participants who participate in organized markets will not sell power even further in advance of the operating hour, making replacement power even less likely to be sourced.

Third, by establishing that WRAP deliveries are non-firm, this BPM prioritizes WRAP holdback delivery below potential contracts that do not even qualify as capacity in the forward showing, which PacifiCorp finds counterintuitive.

Additionally, section 4 requires a Participant anticipating Energy Delivery Failure to ensure the energy profile on the e-tag accurately reflects the expected non-delivery. Based upon common industry practice, it is the receiver of holdback who would have been responsible for prescheduling the e-tag, and therefore is the entity able to modify the energy schedule in real time. Due to this, the BPM does not address circumstances in which an entity neglects or refuses to reduce an energy schedule to reflect anticipated non-delivery.

03: Please supply any comments related to the Calculation of Delivery Failure Charge section (4).

The BPM needs to clearly state which index prices will be used for each of the subregions – i.e., MID-C subregion will use the MID-C index price and the SWEDE subregion will use the Palo Verde index price. For hours where the day-ahead and real-time market prices are negative, the BPM states that the highest price between both markets over the last 30 days will be used. Is this on an hourly basis or will the highest price be used for all hours that there was a delivery failure? If a failure occurred during HE20 will WRAP compare past day-ahead and real-time prices for just HE20, or the highest of any hour in the last 30 days?

Additionally, the circumstances which a participant is subject to the 50x multiplier when failing to deliver energy. Under the non-covered delivery failure section, there is language that reads second or more non-waived energy delivery failure in a cumulative delivery failure window (regardless of whether the first non-waived energy delivery failure was covered or non-covered). The sentence in the parenthesis seems to contradict with the multipliers listed in the “covered” delivery charge section. The language implies that they would always be subject to the 50x multiplier and not the scaled approach for “covered” as seen in the section above.

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).

PacifiCorp notes this proposal will require a separate “checkout” function for WRAP deliveries to both ensure Participants agree with any charges for failure to deliver, and that Participants are appropriately compensated via the allocation process in Section 6, which could be protracted as there is the possibility of multiple failures to deliver the same amount of energy, as the required amount fails from the initial deliverer, who may or may not have a waiver, and moves to a second deliverer that who may also fail and request a waiver.

06: Please supply any comments related to the Waiver of an Energy Deployment Obligation section (7).

PacifiCorp is of the opinion the provisions in Section 7 are too vague. PacifiCorp would like to see the waiver form included in the BPM as an attachment, as the form itself may impose requirements not otherwise subject to a review or governance process. By omitting the form from the BPM review process, Participants are unable to determine the nature of information needed to substantiate a delivery failure. Given the magnitude of scrutiny on reliability events, it may be reasonable to expect Participants would need to provide EMS data, call logs, or similar proprietary data, but that is not known by omitting the waiver form from this BPM.

In the list of potentially valid justifications for a waiver, item number one provides significant leeway, as ‘maintain system reliability’ affords many interpretations, some of which not all Participants may agree are valid.

Additionally, regarding item number one, losses and derates of generation resources routinely occur, and providers of WSPP Schedule-C firm energy (a product WRAP does not include in a Participant’s Forward Showing) are expected to replace that committed energy. A generation loss or derate does not constitute a valid reason to curtail WSPP Schedule-C energy. Also, this section does not include industry standard terms such as “unplanned” or “emergency loss”. This section also does not specify the generation loss or derate is for a reason outside of operator control or is inexcusable because the Participant failed or was otherwise unable to procure sufficient fuel.

07: Please supply any comments related to the Possible Expulsion for Repeated Energy Delivery Failures section (8).

No response submitted.

General Comment