01: Please supply any comments related to the Introduction, Definitions, or Background sections.
The first sentence in the Introduction references exigent circumstances as defined in the Tariff, but we believe we should also reference BPM 303 Expedited Review Process in this section as that is the BPM that covers concepts with exigent circumstances.
The third paragraph in the Background section discusses what happens when a concept is approved to be included in the Workplan, but doesn’t speak to what happens to those concepts not approved. APS would recommend including what happens to those in this section or reference BPM 301 Workplan Development if that is more appropriate.
02: Please supply any comments related to Proposal Development section (3).
No comments at this time.
03: Please supply any comments related to the Proposal Development - Task Force Creation section (3.1).
It is unclear to us if Task Force membership is limited to only WRAP Participants, or can other interested parties and stakeholders be nominated for consideration of inclusion in the Task Force by the PRC?
04: Please supply any comments related to the Proposal Development - Proposal Drafting Process section (3.2).
The list of items the Proposal includes is indicating that all are needed for a complete Proposal. If this is the case I wonder if the alternative updates considered could be “if applicable” so that we don’t create alternative updates for the sake of checking the box that we have included all the items in the list for the Proposal.
The list also includes a proposed implementation timeline, which is fine from a Proposal completeness perspective, but APS would be concerned with the implementation timeline of multiple Proposals being sequential resulting in Participants always preparing for the next change. Something that has worked well in similar environments, is to have a standard release schedule for changes – Potentially something like in the shoulder months before each Binding Season could make sense in the WRAP context for standard enhancement release timeframes Participants could follow and be prepared for.
In terms of sequence, it may be beneficial to switch the order of 3.2.2 and 3.2.3. That way it reads the Proposal is ready for comment followed by the comment format, as written it could be taken that the comment format is for a different comment period than the one that occurs after the Proposal is ready for comment. Alternatively, 3.2.2 could move down to section 4.
05: Please supply any comments related to the Proposal Review section (4).
No comments at this time.
06: Please supply any comments related to the Proposal Review - Public Comment section (4.1).
It is unclear at the end of this section when the Task Force informs the PRC of changes, does the PRC need to approve the changes since the PRC is the body that approved the original Proposal as complete and ready for comment. It looks like the PRC reviews them in section 4.3 when the PRC decides to recommend the Proposal to the RAPC, but it may be good to add that in this stage the Task Force doesn’t need explicit approval of changes made to the Proposal.
07: Please supply any comments related to the Proposal Review - COSR Comments section (4.2).
It appears this section is speaking to a 2nd opportunity and a specific audience of the COSR to comment, but it is not mentioned as to why this is needed since the COSR could comment in the initial public comment period outline in section 4.1.
08: Please supply any comments related to the Proposal Review - PRC Recommendation Process section (4.3).
This section refers to endorsement in the first sentence of 4.3.1.1 rather than recommendation of the Proposal to RAPC, probably should be consistent in terminology between sections with use of recommendation.
09: Please supply any comments related to the Proposal Review - RAPC Review section (4.4).
The beginning of this section contradicts the previous section in which the PRC determines to recommend to RAPC since it will go to RAPC either way. We should probably include that in the sections above so that readers do not assume that if it is not recommended by PRC that it stops because they don’t read section 4.4.
In section 4.4.2.1 line 3 mentions “approved” by RAPC but it appears RAPC is recommending, terminology alignment needed here again we think. Also, in this section it says PRC will summarize the comments received, is this suppose to be the PRC or is it RAPC that would do this since that is the body that changed the Proposal and initiated the need for the additional two-week comment period?
In section 4.4.3.1 the Proposal could be appealed to the Board due to RAPC rejection or for non-action within 30 days after the PRC action by the RAPC. Is the 30 days business or calendar days, and is this time sufficient to make the agenda of a RAPC for action on the Proposal? If the appeal is based on non-action in the timeframe when does an appellant need to inform the Board of it’s appeal by and how would they do so?
10: Please supply any comments related to the Proposal Review - COSR Formal Opposition to Endorsed Changed Proposal section (4.5).
This section appears to be duplicative of 4.4.2.1.
11: Please supply any comments related to the Proposal Review - Board Interaction section (4.6).
In the bulleted list, on the 2nd bullet this should probably be amended to include appeals for non-action of RAPC as discussed in 4.4.3.1.
General Comment
In past PRC meetings a swim lane diagram has been shown that we believe depicts the steps outlined in this BPM – If that is accurate, APS would request that the diagram be added to the BPM.
We are unsure of the cause, but when you open the document in your browser or in Adobe the tab displays “Forward Showing Business Practice Manual”, but this is a Stakeholder Engagement Business Practice Manual (300 Series).