01: Please supply any comments related to the text in RED.

PacifiCorp appreciates the committment of the WRAP to utilize operational data to determine an approrpriate uncertainty factor. PacifiCorp will look forward to further exploration of an Uncertainty Factor more granular than a flat percentage applied to every Participant applied across every hour of a binding season.

02: Please supply any additional comments on this BPM.

PacifiCorp does not support the concept of reducing the Uncertainty Factor in the preschedule timeframe. The WRAP tariff does not oblige WPP to implement this practice. Reducing the Uncertainty Factor, thereby increasing a Participant's exposure to Holdback obligations, risks putting a Participant in a position of insufficient operating reserves on the operating day. 

BPM 209 - Energy Delivery Failure Charge creates a provision that a non-delivery waiver can be granted to a Participant if the Participant can prove it needed more Uncertainty MW's than calculated in the preschedule WRAP Sharing Calculation. When the Uncertainty Factor is reduced because a WRAP subregion as a whole is short, a regional stress event (heat wave, cold snap) is likely to be taking place. Participants assigned a Holdback obligation in these instances are far less likely to deliver. PacifiCorp is concerned Participants will begin to question the reliability of the WRAP holdback product should non-delivery become a repeat occurrence.

General Comment