01 Please supply any comments related to the Introduction, Definitions, or Background sections.
No comments in this section
02 Please supply any comments related to the Applicable Index Prices section.
A slight correction to move “(FMM)” to after the words “fifteen minute market) since “market” is the 2nd M in FMM.
03 Please supply any comments related to the Settlement Pricing Overview and Components introduction section.
“Section 4.6 of this BPM shows how to allocate the Make Whole Adjustment when there is a single Participant with a Holdback Requirement that is being allocated to multiple deficit Participants. The Participant with the Holdback Requirement should receive a Make Whole Adjustment equal to their maximum total Holdback Requirement. The obligation for providing the Make Whole Adjustment can will/shall be shared among multiple Particpants.”
04 Please supply any comments related to the Settlement Pricing Overview and Components - Total Settlement Price section.
“Energy Declined Settlement Price” is used to price delivered energy – should a different term be utilized? Or is it possible to better explain why this is called Energy Declined in the BPM?
05 Please supply any comments related to the Settlement Pricing Overview and Components - Holdback Settlement Price section.
No comments in this section
06 Please supply any comments related to the Settlement Pricing Overview and Components – Energy Declined Settlement Price section.
No comments in this section
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.
“A Participant that provides energy to another Participant” – unclear if there is a 3rd participant or only 2 with the wording provided.
“negative Sharing Requirement/Calculation” – does the negative requirement mean the participant needed to be a recipient for holdback/delivery?
08 Please supply any comments related to the Settlement Pricing Overview and Components - Make Whole Adjustment section.
No comments in this section
09 Please supply any comments related to the Settlement Pricing Overview and Components - Allocation of Holdback Settlement to Multiple Participants section.
An example of how this allocation of holdback settlement to multiple participants would be helpful in spreadsheet form for further evaluation.
10 Please supply any comments related to the Settlement Pricing Overview and Components - Transmission Service section.
Recommend adding additional clarification that transmission will not be considered by the PA in WRAP transaction settlements in the same Subregion. As written, it just says the Tariff does not address this situation but could be interpreted that it should still be settled among WRAP participants. Transactions in the Operations Program take place at participant provided locations in which they are individually responsible for the transmission cost to and from locations provided.
11 Please supply any comments related to the Settlement Pricing Overview and Components - Settlement Pricing for Subregions section.
No comments on this section.
General Comment
APS would like to request a structured test scenario involving holdback and energy deployment to assist settlements personnel in implementing validations for WRAP transactions.
Comments from previous BPM 206 that may be relevant to BPM 207:
Will WPP establish standard settlement terms between participants?
Is there guidance on how disputes will be handled in case a participant does not agree with any of the settlement calculations?
How will the quantities and values be provided to the Settlements team? We would prefer an SFTP site. (The Total Settlement Price; The Holdback Settlement Price; The Energy Declined Settlement Price; Any Make Whole Payments; and The total settlement amount owed.)
How will the transaction data be provided to the PO?
Receiving the pricing data 10 after receipt of transaction data from participants is long (7 BD after operating day +3 BD after receipt of data) – could run into issues with Settlements close process if event occurs at end of the month.