01: Please supply any comments related to the Introduction, Definitions, or Background sections.
Slight typo in 1.3 “provided” should be “provide”.
02: Please supply any comments related to the Confirming and Declining Energy Deployment section (3).
No comments at this time.
03: Please supply any comments related to the Tagging and Scheduling section (4).
APS has the understanding that an e-tag can only be adjusted by the author of the e-tag which is authored by the deficient entity according to this section, however the responsibility to take action on the e-tag is placed on the surplus Participant. Depending on what action is expected the surplus entity may not be able to, for example if the holdback was requested to be deployed the surplus entity could not adjust the e-tag created by the deficit entity. APS requests clarification on the expectation to take action of the surplus entity in this regards.
04: Please supply any comments related to the Tagging and Scheduling - Energy Deployment Transmission Requirements section (4.1).
APS requests that the transmission check that occurs at ~1600 of the pre-schedule day for the SWEDE region be added here to highlight that transmission availability can and will likely change from time Participants submit the transmission availability to and from delivery points till the time in which the transaction is effectuated through transmission procurement and e-tagging. If this occurs the energy failure delivery charge is to not apply if alternative arrangements can not be made.
05: Please supply any comments related to the After-the-Fact Energy Deployment Information section (5).
Is the ATF deployment information something that should be submitted to the same location as the Operations Program information after the fact file, or how should this information be communicated to SPP as the Program Operator? Alternatively, WPP or SPP could be carbon copied on the e-tag between participants that would allow for the PA and the PO to see any delivered holdback, and would ease the data burden on Participants.
06: Please supply any comment related to the Raise Hand Tool section (6).
The way in which this section is written implies that only a deficit entity can use the raise hand feature because it states, “…this is excess of assistance provided by Holdback Capacity or Energy Deployments” which means only those with deficit sharing calculations could raise their hand. APS believes that the raise hand tool could be used by all participants regardless of sharing calculation results.
General Comment
No comment at this time.