COMMENT FOR Non-Task Force Proposal 2024-NTFP-1

Submitted July 9, 2024, 3:01 p.m.





01: Please supply any comments related to corrections in the Definitions Section

No response submitted.

02: Please supply any comments on redlines to Tariff section 7 (Credit Requirements and Settlement for Holdback and Delivered Energy)

Newly added section 7.2.1 stipulates that a Participant may not invoke the Dispute Resolution Procedures to dispute data inputs or to request the use of alternative data.

It would be beneficial to obtain clarification regarding the input data as it could potentially contain erroneous data.

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)

No response submitted.

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)

No response submitted.

10: Please supply any comments on redlines to Tariff sections 17.2.7 and 17.2.8 (relating to Forward Showing Deficiency Charge)

No response submitted.

11: Please supply any comments on redlines to Tariff section 19.1 (relating to Operations Program Timeline and Supporting Information

Section 19.1 infers that the sharing calc is always indicative. It should state that the sharing calc is binding on the preschedule day.

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)

The Sharing calculation formula likely contains an incorrect sign with regards to the DR Capacity resources.

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)

Holdback Requirement is potentially missing some edits. It reads as “Requirements will prioritize offers of Voluntary Holdback".

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)

The impact of this change on participant Operations should be evaluated.

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

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