01 Please supply any comments related to the Introduction, Definitions, or Background sections.
In section 1, it states “… WRAP allows a Participant facing a calculated resource deficiency … to require Participants with surplus resources to sell …”. It seems that the Tariff/program requires this action, not the Deficient Participants.
02 Please supply any comments related to the Applicable Index Prices section.
No comment.
03 Please supply any comments related to the Settlement Pricing Overview and Components introduction section.
“Holdback Requirement not deployed” could be replaced with “Unheld Energy and Energy Declined” for clarity.
Regarding pricing for voluntary holdback and energy deployment, should the tariff pricing apply to Make Whole Adjustments in addition to Holdback Requirements and Energy Deployments?
04 Please supply any comments related to the Settlement Pricing Overview and Components - Total Settlement Price section.
The design document specifies that if there is no high priced day in the current relevant season, the most recent HPD from the prior relevant season is used. This language is not included in the BPM.
05 Please supply any comments related to the Settlement Pricing Overview and Components - Holdback Settlement Price section.
No comment.
06 Please supply any comments related to the Settlement Pricing Overview and Components – Energy Declined Settlement Price section.
I have raised this comment before, but Energy Declined Settlement Price is a misnomer, this should be named Energy Deployed Settlement Price.
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.
Final Settlement Revenue (FSR) should be defined as including Holdback Settlement and Energy Deployment Settlement. FSR should be described in a formula as well as in the text.
There are references in this section to a reduction in payments to Surplus Participants and a credit to Deficient Participants based on the Energy Declined Settlement price multiplied by the MWh of energy declined. Including mention of this credit in section 4.4 implies that this component should be included in FSR, which also includes Holdback Requirement payments and Energy Deployment payments. This credit is also included in section 4.5 (Make Whole Adjustment or MWA) as the Real-time Value of Energy Declined. If this wording was intentional, the credits in the FSR and MWA cancel each other out, artificially reducing the FSR and increasing the MWA to offset.
This language is unclear, “A Participant that had a negative Sharing Requirement 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”. Although this has been copied from the tariff, specifying that that the Deficient Participant reserved the Holdback during the Preschedule opt-in process might offer more clarity.
In the section describing which payments a Deficient Participant is responsible for, it includes Holdback Settlement, Make Whole Adjustment, and a credit for Energy Declined (which, as mentioned above, is problematic). It omits any reference to payment for Energy Deployed.
08 Please supply any comments related to the Settlement Pricing Overview and Components - Make Whole Adjustment section.
Non-dispatched energy is an undefined term, replace with “Unheld Energy and Energy Declined”.
Possible Block Sale Revenue is undefined, include a definition and formula.
As mentioned in Comment 7, Final Settlement Revenue is undefined, include a definition and formula in Section 4.4.
We will raise this comment again, the price for Real-Time Value of Energy Declined should be the Real-Time index price, as this represents the seller’s opportunity cost.
The Make Whole Adjustment cannot be less than zero.
09 Please supply any comments related to the Settlement Pricing Overview and Components - Allocation of Holdback Settlement to Multiple Participants section.
We recognize that this is a newly developed section, but it still needs work. This section consists mostly of examples that are hard to follow, and would benefit from more specific definitions of terms, specific language about how the calculations are applied, inclusion of formulas and tables demonstrating the methodology.
The title for this section should be Allocation of Make Whole Adjustments to Multiple Participants.
10 Please supply any comments related to the Settlement Pricing Overview and Components - Transmission Service section.
No comment.
11 Please supply any comments related to the Settlement Pricing Overview and Components - Settlement Pricing for Subregions section.
No comment.
General Comment
For clarity, it would be helpful to qualify references to Participants as Surplus Participants or Deficient (Deficit) Participants throughout this BPM.
Inclusion of formulas wherever possible, such as in section 4.5, would be very helpful.