01 Please supply any comments related to the Introduction, Definitions, or Background sections.
NV Energy appreciates the opportunity comment and offers the following comments for the Western Power Pool’s consideration. NV Energy believes it would be helpful to understand the reasoning behind the 10% adder that is included in the total settlement price. The settlement calculation incorporates a make whole payment if the participant that supplied the holdback did not receive enough revenue to recover the cost for selling the energy in the market. Therefore, it is unclear why an additional 10% is necessary as an adder for the total settlement price.
02 Please supply any comments related to the Applicable Index Prices section.
No response submitted.
03 Please supply any comments related to the Settlement Pricing Overview and Components introduction section.
No response submitted.
04 Please supply any comments related to the Settlement Pricing Overview and Components - Total Settlement Price section.
NV Energy recommends that more specificity be included in this section. For instance, it is unclear whether or not the most recent high-priced day for the relevant season could be from the previous year. Additionally, NV Energy does not understand how the average Day Ahead SMEC is calculated.
05 Please supply any comments related to the Settlement Pricing Overview and Components - Holdback Settlement Price section.
No response submitted.
06 Please supply any comments related to the Settlement Pricing Overview and Components – Energy Declined Settlement Price section.
No response submitted.
07 Please supply any comments related to the Settlement Pricing Overview and Components - Application of Pricing and Quantities for Holdback Requirements and Energy Deployment Transactions section.
This section indicates that a participant would pay a holdback for any instance that the participant was calculated to be in deficit by the surplus calculation. NV Energy does not believe this is the intent of the program and offers the following revision for consideration in the Business Practice.
“A Participant that had a negative Sharing Requirement and elected to receive holdback for any hour of an Operating Day, which was incorporated in the calculation of Holdback Requirements of any Participants for such hour, determined as of the Preschedule Day, shall pay the Holdback Settlement Price times the MW quantity of such negative Sharing Requirement.”
08 Please supply any comments related to the Settlement Pricing Overview and Components - Make Whole Adjustment section.
No response submitted.
09 Please supply any comments related to the Settlement Pricing Overview and Components - Allocation of Holdback Settlement to Multiple Participants section.
No response submitted.
10 Please supply any comments related to the Settlement Pricing Overview and Components - Transmission Service section.
No response submitted.
11 Please supply any comments related to the Settlement Pricing Overview and Components - Settlement Pricing for Subregions section.
No response submitted.
General Comment