01: Please supply any comments related to the Introduction, Definitions, or Background sections.

No response submitted.

02: Please supply any comments related to the Confirming and Declining Energy Deployment section (3).

“Any Participant for which the Program Operator calculated during the Preschedule Day a negative Sharing Requirement for the hour in question shall have zero Holdback Requirement and shall not have any Energy Deployment obligation for that hour.”

While this language is consistent with BPM 204, Tacoma would like to allow for the possibility that a deficit Participant (per the Sharing Calculation) that does not request or Opt-In for Holdback Capacity should still be able to offer resources to the WRAP via Voluntary Holdback. In that case the language above would need to be adjusted.

03: Please supply any comments related to the Tagging and Scheduling section (4).

Tacoma notes the timeline from T-85 to T-60 for the creation, or even adjustment, of tags between deficit and surplus participants is very limited and may result in missed deadlines and incorrect tags.

Since both participants will need to reserve enough transmission to possibly deliver/receive the maximum about of the Holdback Capacity assigned during Preschedule until the T-85 deadline anyway, Tacoma suggests tags be created on the Preschedule Day whenever possible.

04: Please supply any comments related to the Tagging and Scheduling - Energy Deployment Transmission Requirements section (4.1).

No response submitted.

05: Please supply any comments related to the After-the-Fact Energy Deployment Information section (5).

If a tag curtailment results in a lower Energy Delivery than agreed, would the curtailment reason/curtailing entity etc., be relevant information for this purpose?

06: Please supply any comment related to the Raise Hand Tool section (6).

No response submitted.

General Comment