Submitted Responses
BPM 204 - Holdback Requirement
01: Please supply any comments related to the Introduction, Definitions, or Background sections.
02: Please supply any comments related to the Sharing Calculation Run (3).
03: Please supply any comments related to the Confirmation of Need for Holdback Capacity (4).
04: Please supply any comments related to the Voluntary Offers section (5).
Section 5 does not clearly state what excess supply is not obligated to the WRAP. Therefore, NV Energy proposes that WPP add a formal definition for voluntary offers or add in additional detail that clearly demonstrates what capacity is considered excess supply that may be offered into the program as a voluntary offer.
05: Please supply any comments related to the Optimization Allocation section (6).
06: Please supply any comments related to the Optimization Allocation - Subregion with Central Hub section (6.1).
07: Please supply any comments related to the Optimization Allocation - Subregion without Central Hub section (6.2).
08: Please supply any comments related to the Optimization Allocation - Ensuring Whole MW Holdback Capacity section (6.3).
09: Please supply any comments related to the Bilateral Transfer of Holdback section (7).
10: Please supply any comments related to the Release of Capacity section (8).
NV Energy proposes that Section 8 use the term surplus rather than the term holdback. Section 8 identifies instances where surplus could be released and may not be necessary for holdback for another program participant. As it is currently written, section 8 could be interpreted that the holdback that has been claimed from a deficient participant as outlined in section 4 could lose this claim for the reasons stated in section 8.
11: Please supply any comments related to the Release of Capacity - Program Early Release of Holdback section (8.1).
12: Please supply any comments related to the Release of Capacity - Participant Petition for Early Release of Holdback section (8.2).
13: Please supply any comments related to the Release of Capacity - Holdback not claimed on the Preschedule Day section (8.3).
General Comment
NV Energy appreciates the opportunity to comment in the Western Power Pool’s (WPP) Business Practice Manual process and offers the following comments for consideration. NV Energy recommends that the Point to Point Limits (PTPL) file and the Point Limit (PL) file definition include the specific location where the document will be posted within the WPP website. The current definition does not clearly state where a participant or stakeholder can find the documents.