01: Please supply any comments related to the Introduction, Definitions, or Background sections.
No comments at this time.
02: Please supply any comments related to the Sharing Calculation Run (3).
No comments at this time.
03: Please supply any comments related to the Confirmation of Need for Holdback Capacity (4).
In the last sentence is there a time on the pre-schedule day that can be added in which the Participant needs to confirm by before they are considered not needing the assistance?
04: Please supply any comments related to the Voluntary Offers section (5).
The first sentence in this section could be interpreted as to preclude the ability to offer voluntary assistance if you are obligated to provide holdback, but they may have additional above their obligation they would like to make on a voluntary basis but wouldn’t be able to based off the first sentence that reads, “Participants with excess supply that are not obligated to the WRAP through their positive Sharing Calculation result may voluntarily offer such supply to the WRAP as Voluntary Holdback.”
05: Please supply any comments related to the Optimization Allocation section (6).
No comments at this time.
06: Please supply any comments related to the Optimization Allocation - Subregion with Central Hub section (6.1).
In 6.1.1 the second bullet says see more below but the table one would look at naturally below is relevant to the third bullet in the section. Is there a way to better instruct the reader on where below to look for more information, or update the calculation imbedded below the third bullet to include the 2nd bullet calculation?
APS believes the 2nd sentence in 6.1.2 should be, “….is capped at the sum of the positive Sharing Calculation results in Section 3 for each surplus participant in the Subregion. Also in 6.1.2 APS believes the words before the calculation should be amended to align with the terms in the calculation, for example “sum of the requested Holdback Capacity” is used in the section while the calculation uses “Total Assistance”, we believe this is the same thing and should be referred to in a consistent fashion.
07: Please supply any comments related to the Optimization Allocation - Subregion without Central Hub section (6.2).
No comments at this time.
08: Please supply any comments related to the Optimization Allocation - Ensuring Whole MW Holdback Capacity section (6.3).
No comments at this time.
09: Please supply any comments related to the Bilateral Transfer of Holdback section (7).
The first sentence should be amended to be “Participant (A) may agree with any other surplus Participant (B)”.
10: Please supply any comments related to the Release of Capacity section (8).
No comments at this time.
11: Please supply any comments related to the Release of Capacity - Program Early Release of Holdback section (8.1).
No comments at this time.
12: Please supply any comments related to the Release of Capacity - Participant Petition for Early Release of Holdback section (8.2).
No comments at this time.
13: Please supply any comments related to the Release of Capacity - Holdback not claimed on the Preschedule Day section (8.3).
No comments at this time.
General Comment
No comments at this time.