01 Please supply any comments related to the multi-day-ahead assessment and release.

Is multi-day-ahead release only for Day + 5-7? The current set up of figure 1 makes it appear so.  

Regarding figure 1: Why is the pre-schedule day on Friday at the end of the multi-day data submission. The pre-schedule day is at the beginning of the timeline which would cover Sunday-Monday. Can we add what day it is today to the figure? 

02 Please supply any comments related to the preschedule day.

In the first paragraph, regarding the mention of the Sharing Calculation: This could use some clarification around that the sharing calculation is re-ran but is not going to change holdback requirement. May not need to include the re-run language as the sharing calculation is always re-ran after pre-scheduling day even when it is not before the OD. 

Are participants actually exchanging holdback in the PIT? Would this not be done through phone and deal capture of transactions? 

At the end of this section there is a non-visible Link to timeline, figure 2, should link be visible and say, “presented in...Figure 2”?  

Figure 2 Comments:  

• FS box at 0520 makes it appear you have to submit something related to FS at 05:20. Believe the intent is to just depict that information from the FS 7 months in advance is utilized in the sharing calculation. 

• 2A-2C Submittal & 1A + 1A2 1B Submittal: Transmission submission will be done by participants as automated standard file submission not after posting of results if there is no new information on participant specific deficit to allow for customized points to a specific participant. Voluntary may make sense to have in parallel.  

• What is 1A2 it is not in data spec file? 

• Prior to start of Operating Day: Need an additional box for transmission procurement in SWEDE region by 16:30.  

• After the Fact Data Submission: What is the need for after the fact data submission within two hours of the hour ending? Couldn't this be a daily submission? The timeline doesn’t depict the frequency of submission but is noted in the data specification document at no later than 120 minutes after the hour.  

03 Please supply any comments related to the operating day.

Recommend for clarity to change first sentence to “deficit participant final opportunity to accept energy delivery of holdback is at T-120”. Suggest to also identify who is responsible for tagging after the T-120, probably should be deficit entity and, they should communicate accepted energy delivery to the surplus participants real-time desk. 

04 Please supply any comments related to the current format, structure, contents of the business practice - as it relates to a template for all business practices to follow.

No comment.

General Comment

APS is requesting to make the BPM comment template's downloadable, this would make it much easier to collaborate internally on organization comments and input. Currently have to recreate the comment template on own in word for internal collaboration.