01: Please supply any comments related to the Introduction, Definitions, or Background sections.
No response submitted.
02: Please supply any comments related to the Sharing Calculation Run (3).
No response submitted.
03: Please supply any comments related to the Confirmation of Need for Holdback Capacity (4).
No response submitted.
04: Please supply any comments related to the Voluntary Offers section (5).
Is the Input Data File Specification intended to be a public or confidential document? Please provide a link or further direction on where to locate this resource on WPP’s website. PacifiCorp recommends WPP create a central repository for WRAP related forms and resources referenced in BPMs.
What purpose does submitting Voluntary Holdback ahead of the preschedule day serve? In mentioning this, the BPM should clarify if Participants who expect to be deficient can claim or call upon Voluntary Holdback beyond the Preschedule Day. If Participants can only confirm a need for Holdback on the Preschedule Day, despite Voluntary Holdback being offered further out in time, that should be restated here.
05: Please supply any comments related to the Optimization Allocation section (6).
No response submitted.
06: Please supply any comments related to the Optimization Allocation - Subregion with Central Hub section (6.1).
No response submitted.
07: Please supply any comments related to the Optimization Allocation - Subregion without Central Hub section (6.2).
No response submitted.
08: Please supply any comments related to the Optimization Allocation - Ensuring Whole MW Holdback Capacity section (6.3).
No response submitted.
09: Please supply any comments related to the Bilateral Transfer of Holdback section (7).
Please detail what, if any feasibility check is performed by the PIT when a bilateral transfer of Holdback occurs.
Due to industry convention and WRAP requirements, it will be the receiving Participant who ends up needing to re-tag the Holdback delivery if a bilateral transfer occurs. Please elaborate on what recourse a receiving Participant has if a failure occurs, or if the transfer is infeasible for the receiving Participant.
In particular, transmission availability changes from Preschedule Day to Operating Day. If Participant A is scheduled to receive Holdback from Participant B, and Participant B transfers its Holdback obligation to Participant C, but Participant A does not have sufficient inbound transmission available from Participant C, what is the outcome? Please cover this and other avenues of recourse Participant A would have if there is a failure or error between Participant B and Participant C.
10: Please supply any comments related to the Release of Capacity section (8).
PacifiCorp does not understand why WPP would release capacity into the future, when significant, catastrophic regional events can happen at any time. This introduces subjectivity which could potentially be an issue.
11: Please supply any comments related to the Release of Capacity - Program Early Release of Holdback section (8.1).
No response submitted.
12: Please supply any comments related to the Release of Capacity - Participant Petition for Early Release of Holdback section (8.2).
No response submitted.
13: Please supply any comments related to the Release of Capacity - Holdback not claimed on the Preschedule Day section (8.3).
No response submitted.
General Comment