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).
No response submitted.
03: Please supply any comments related to the Protection of Confidential or Commercially Sensitive Information Section (4).
No response submitted.
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).
No response submitted.
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).
Tacoma Power understands the value in WPP producing composite and aggregate reports to inform stakeholders about the program and appreciates the opportunity to review the form and format of those reports to ensure that confidential information cannot be determined from them. We request that the WPP consider extending the current fourteen-day comment period. For example, a twenty-one-day comment period would carry less risk that it could be provided to an organization at a time when an existing operational issue could require extra time for review.
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).
Tacoma Power appreciates WPP’s recognition that changes in participation could impact the potential to calculate confidential information from a previously approved composite or aggregate report. We request that WPP consider whether the time to object based on a change in participation should begin to run after the next preparation of the relevant composite or aggregate report following the change in WRAP participation. Requiring any objection following a change in WRAP participation, but prior to WPP’s completion of the next following report, could require each participant to maintain a duplicative working knowledge of the WPP’s methods of compiling reports and an ability to duplicate them. Triggering the obligation from the next report would be consistent with the Tariff language in 10.2.1.4 that requires an objection to be raised “promptly following the change in composition” but does not further define “promptly.”
11: Please supply any comments related to the RAPC Decision to Release Participant-Specific Information section (7).
No response submitted.
General Comment