01: Please supply any comments related to the Introduction, Definitions, or Background sections.
No response submitted.
02: Please supply any comments related to the Designation of Confidential or Commercially Sensitive Information Section (3).
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.
03: Please supply any comments related to the Protection of Confidential or Commercially Sensitive Information Section (4).
There appears to be language that has been extracted from Section 10 of the WRAP Tariff and used in this section of the BPM. Powerex suggests that Section 4 be revisited to avoid duplication of Tariff language. Powerex suggests that appropriate references to Section 10 of the WRAP Tariff would suffice and would simplify the BPM.
04: Please supply any comments related to the General Exceptions section (4.1).
No response submitted.
05: Please supply any comments related to the Composite or Aggregated Information section (4.2).
No response submitted.
06: Please supply any comments related to the Required Disclosures section (4.3).
Powerex suggests the Section 4.3.2 should elaborate and describe what “reasonable time”, as outlined in Section 10.4.2 of the WRAP Tariff, would be in terms of disclosure to FERC.
07: Please supply any comments related to the Composite or Aggregated Information section (5).
No response submitted.
08: Please supply any comments related to the Disclosing Entity Review section (5.1).
No response submitted.
09: Please supply any comments related to the Disclosing Entity Appeal section (5.2).
No response submitted.
10: Please supply any comments related to the Objection to Format for Change in Participants section (6).
No response submitted.
11: Please supply any comments related to the RAPC Decision to Release Participant-Specific Information section (7).
No response submitted.
General Comment