COMMENT FOR BPM 207 - Settlement Process

Submitted April 1, 2024, 3:49 p.m.



01: Please supply any comments related to the Introduction, Definitions, or Background sections.

The Introduction says “…Tariff directed transactions are known as Holdback Requirements (see BPM 204 Holdback Requirement) and Energy Deployments (see BPM 205 Energy Deployment).” – It would be helpful to add what the terms Holdback Requirement and Energy Deployment are at the end of the sentence, or in the Definitions. For example, “Holdback requirement is a MW quantity determined on a prescheduled day that a participant is required to be capable of converting into an Energy deployment on a given hour of the succeeding operating day.”

The Background section states “Prices and Final Settlement Revenue...will be made available to any Participant having a Holdback Requirement or Energy Delivery transaction. However, the following section says the Total Settlement Price will be publicly available, these sentences don’t fit together well for readers to understand.  Is it public or only available to participants with a transaction?

02: Please supply any comments related to the What Settlement Information is Posted section (3).

Is there more specificity available to be added in this document related to transaction details?  Things like date, time, location delivered, quantity requested,  and quantity delivered are all items that would make validation easier for Participants. 

03: Please supply any comments related to the How Settlement Information is Accessed section (4).

No comment at this time.

04: Please supply any comments related to the Timeline section (5).

No comment at this time.

05: Please supply any comments related to the Timeline - Unavailability of external Input Data section (5.1).

It is unclear in this section if alternative data would be utilized when the Applicable Index Price or the Hourly Shaping Factor is not available, since it is noted a BPM 206 change would be required, which needs Board approval. Is the PA going to use alternative data, or should WRAP Participants seek to agree amongst each other the terms of the transaction?06: Please supply any comments related to the Timeline - Changes to Inputs after Settlement Values have been Calculated section (5.2).

This section notes a notice of re-calculation will be sent to all Participants; however, it doesn’t expand if those Participants may appeal the re-calculated settlement? Would the re-calculation trigger an additional 90-day dispute period?

06: Please supply any comments related to the Timeline - Changes to Inputs after Settlement Values have been Calculated section (5.2).

This section notes a notice of re-calculation will be sent to all Participants; however, it doesn’t expand if those Participants may appeal the re-calculated settlement? Would the re-calculation trigger an additional 90-day dispute period?

07: Please supply any comments related to the Dispute Resolution Process section (6).

No comment at this time.

General Comment

No comment at this time.

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