01: Please supply any comments related to corrections in the Definitions Section
Demand Response Capacity Resource: Please explain the intent of the phase “utilize exclusively to meet a Participant’s FS Capacity Requirement”. Specifically, How is this expected to impact a Participant’s ability to claim DR in their FS? Will this increase the data submittal burden to prove exclusivity? Will this elevate the bar for claiming DR making it difficult to get credit for DR programs in the FS? If the answer is that this will not make it more difficult to get credit for DR programs, please explain why with BPM and tariff references.
Demand Response Load Modifier: What does “demonstrated mean” where are the demonstration requirements outlined? Please explain the intent of the phase “utilize exclusively to meet a Participant’s FS Capacity Requirement”. Specifically, How is this expected to impact a Participant’s ability to claim DR in their FS? Will this increase the data submittal burden to prove exclusivity? Will this elevate the bar for claiming DR making it difficult to get credit for DR programs in the FS? If the answer is that this will not make it more difficult to get credit for DR programs, please explain why with BPM and tariff references.
02: Please supply any comments on redlines to Tariff section 7 (Credit Requirements and Settlement for Holdback and Delivered Energy)
7.2.1 “may not invoke the Dispute Resolution Procedures to dispute data inputs or to request use of alternative data.” This seems contrary to the intent of the program to ensure that we have the right data and that the data requested/used is appropriate for the intended use. Why would alternative data be unilaterally excluded? Why would data that is in dispute not be allowed to go through the resolution process? Entities need to have the necessary protection in place to ensure we get to the right outcome.
02a: Section 9 Prefer any dispute, without limitations.
03: Please supply any comments related to redlines to Tariff section 10.2 (Treatment of Confidential or Commercially Sensitive Information)
No response submitted.
04: Please supply any comments related to redlines to Tariff sections 14.2.1.2, 16.1.5, and 19.2 (relating to Forward Showing Submittal demonstration of inter- subregional transmission in lieu of Capacity)
No response submitted.
05: Please supply any comments on redlines to Tariff sections 16.1.2.1, 16.1.2.3, and 16.2.5.2.2 (related to corrected "annual LOLE" references to "Seasonal LOLE")
No response submitted.
06: Please supply any comments on redlines to Tariff sections 16.1.2, 16.2.5.4, 20.1.1 (related to options for DR)
16.1.3 “and which has met certain testing requirements” Not comfortable with this language, this could be interpreted to mean some type of “test” is required in the BPM. This should be deleted, or different language offered that creates multiple pathways to ensuring a Participant can get appropriate credit for their DR program. Additionally, programs may change from year to year and a “test” may not be allowed or accurate unless completed well after the FS cure period is over. Substantially more latitude is required to accurately capture the value of DR programs. There is little if any incentive to overstate the value and if an entity does overstate the value it will result in additional holdback or loss of delivery for the entity resulting in financial impacts in the Operations Program. This language is unnecessary and will result in reduced credit or no credit for DR programs that are encouraged, even required by a number of PUCs. It is important that each MW of capacity is accounted for accurately, Participants are highly incented to get their FS submission correct and will not be able to do so with overly burdensome or unnecessary testing requirements.
Please explain how it has been determined that the QCC calculation is appropriate for all DR programs in the region. Does this calculation belong in the tariff, or should it be in a BPM? Should the Participant be allowed to submit their own QCC value for the DR program or is there another mechanism to ensure the program is properly valued?
16.2.5.4 Please explain how it has been determined that the QCC calculation is appropriate for all DR programs in the region. Does this calculation belong in the tariff, or should it be in a BPM? Should the Participant be allowed to submit their own QCC value for the DR program or is there another mechanism to ensure the program is properly valued?
07: Please supply any comments on redlines to Tariff section 16.2.7 (relating to Total RA Transfer)
No response submitted.
08: Please supply any comments on redlines to Tariff section 16.2.8 (relating to Planned Outages)
No response submitted.
09: Please supply any comments on redlines to Tariff section 16.3.2 (relating to Transmission Exceptions)
16.3.2 Final appeal before the board doesn’t afford significant protection to participants. Should participants have the opportunity to take their appeal before the RAPC? Or arbitration if there is a disagreement on the interpretation or application of a BPM?
10: Please supply any comments on redlines to Tariff sections 17.2.7 and 17.2.8 (relating to Forward Showing Deficiency Charge)
17.2 “and any Monthly Deficiencies in a previous Forward Showing year”. Please explain why this was added and how it increases or decreases a participant’s potential liability.
11: Please supply any comments on redlines to Tariff section 19.1 (relating to Operations Program Timeline and Supporting Information
No response submitted.
12: Please supply any comments on redlines to Tariff section 19.4 (relating to Operations Program Timeline and Participant Tx Inputs)
No response submitted.
13: Please supply any comments on redlines to Tariff section 19.5 and 20.4.1.2 (relating to reference correction of Subregions not containing a central transmission hub)
No response submitted.
14: Please supply any comments on redlines to Tariff section 19.5 (relating to decription of mechanics of Voluntary Holdback)
No response submitted.
15: Please supply any comments on redlines to Tariff section 20.1.1 (relating to update to description of Sharing Calculation)
“must satisfy testing requirements” Not comfortable with this language, this could be interpreted to mean some type of “test” is required in the BPM. This should be deleted, or different language offered that creates multiple pathways to ensuring a Participant can get appropriate credit for their DR program. Additionally, programs may change from year to year and a “test” may not be allowed or accurate unless completed well after the FS cure period is over. Substantially more latitude is required to accurately capture the value of DR programs. There is little if any incentive to overstate the value and if an entity does overstate the value it will result in additional holdback or loss of delivery for the entity resulting in financial impacts in the Operations Program. This language is unnecessary and will result in reduced credit or no credit for DR programs that are encouraged, even required by a number of PUCs. It is important that each MW of capacity is accounted for accurately, Participants are highly incented to get their FS submission correct and will not be able to do so with overly burdensome or unnecessary testing requirements.
16: Please supply any comments on redlines to Tariff section 20.1.3 (relating to removal of references to lesser priorities of Energy Deployment)
No response submitted.
17: Please supply any comments on redlines to Tariff section 20.2 (relating to description of mechanics of Holdback Requirement)
No response submitted.
18: Please supply any comments on redlines to Tariff section 20.4.1 (relating to how Energy Deployment occurs on Operation Day)
No response submitted.
19: Please supply any comments on redlines to Tariff section 20.4.1.2 and 21.1.4 (relating to reference corrections)
No response submitted.
20: Please supply any comments on redlines to Tariff sections 20.4.2-20.2.4 (relating to corrections to 85 & 80 minutes before the hour)
No response submitted.
21: Please supply any comments on redlines to Tariff section 20.8.1 (relating to incorrect conflation of "Raise Hand" with Voluntary Holdback)
No response submitted.
22: Please supply any comments on redlines to Tariff section 21.2.4 (relating to updating Energy Declined Settlement price to be the Applicable Real-time Index Price for the hour)
No response submitted.
23: Please supply any comments on redlines to Tariff section 21.2.5 (relating to change to Make Whole Adjustment formula)
No response submitted.
General Comment