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).
No response submitted.
03: Please supply any comments related to the Tagging and Scheduling section (4).
There seem to be several problems with this requirement:
- Usually for transmission owner tags: the seller is responsible for transmission from resource to Mid C and the buyer is responsible for transmission from Mid C to load. The deficient party is not the transmission owner responsible for tagging delivery for all legs.
- For multiple legs of transmission: Suggest that the BPM be silent on who tags and let the transaction parties determine it, but still require tagging by T-60.
If the seller (supplying participant) tags energy to mid-c delivery point, but receiving party fails to tag, deliver from mid-c to load, correct actions have been taken on the part of the delivering participant.
Delivery at any other point would be completed through the bilateral agreement of a different delivery point, and the respective transmission owners would be responsible for tagging that delivery
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).
How will this reporting be completed? Need to expand and describe how this After the Fact information is submitted. Is this through the PIT, an email, another system?
06: Please supply any comment related to the Raise Hand Tool section (6).
Suggest adding language that clearly states the ‘Raised Hand’ function is not constrained by the results of the Sharing Calculation; it can be used for any event or time resulting in an ‘unmet energy’. The currently language tries to get to it with ‘in excess of assistance’ but it would be worth expanding to make this very clear. Raised Hands is above and beyond (outside) the Sharing Calculation actions of the program, in both help of MW’s and in settlement.
General Comment
Bonneville appreciates the opportunity to provide comments