COMMENT FOR BPM 209 - Energy Delivery Failure Charge

Submitted Jan. 26, 2024, 2:21 p.m.



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

N/A

02: Please supply any comments related to the Notification of Anticipated Delivery Failure section (3) .

Is completing each of the 4 actions listed in Section 3 sufficient to obtain a waiver?

Is there a precise to timeframe to meet the 4 conditions in order to qualify? 

03: Please supply any comments related to the Calculation of Delivery Failure Charge section (4).

As a point of clarification, if the surplus party can deliver only a portion of the original full delivery amount (see highlighted text), will charges be assessed on the delta qty of MWh ( Original Full delivery amount - Actual Delivery Amount delivered) ?

04: Please supply any comments related to the Dollar Limit on Delivery Failure Charges During a Forward Showing Year section (5).

Can this Participant Dollar Limit be simplified to sum the equivalent FS monthly deficiency charge for the largest (MW) Energy Delivery Failure for each month in the FS Year thus far? 

Why is the 1st bullet point split out? 

Would be great to walk through an example as the methodology seems convoluted. 

05: Please supply any comments related to the Allocation of Revenues from Payment of Delivery Failure Charges section (6).

N/A

06: Please supply any comments related to the Waiver of an Energy Deployment Obligation section (7).

N/A

07: Please supply any comments related to the Possible Expulsion for Repeated Energy Delivery Failures section (8).

N/A

General Comment

No further commetnts

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