01 Please supply any comments related to the multi-day-ahead assessment and release.

On page 4, include references to specific files as outlined in Participant Files Specifications document.

On pages 4 and 5, it states that PO may consider early release of holdback.  Figure 1 indicates this could happen within a 3 day window before OD, with caption indicating this process will be defined in the BPM (which BPM, this one or another?) Since this BPM covers timelines, the release timeline should be specifically spelled out in the text.

Figure 1 is unclear.  Resolve conflicting information on submitting MD assessments and issuing Sharing Calculation results.  On page 4 it states MD is submitted only on scheduling days (generally Mon-Fri). However, Figure 1 depicts MD assessments being submitted on Saturday and Sunday.  On page 5 it states that interim sharing calculations will be run on ‘interim’ days.  Do interim days include Sat & Sun or only scheduling days (Mon-Fri)?  Design document states MD data submission occurs ‘each day’.

On page 4, 'PO may consider' is vague language.  If PO makes decision to release holdback early, how is this communicated to participants?  How is early release reflected in subsequent posted results?

02 Please supply any comments related to the preschedule day.

On page 5, “Exception to default scheduling practices” is redundant as the WECC calendar take into account holidays and new months.

On page 5, it states that the sharing calc performed on preschedule day is binding, but the PO will rerun sharing calcs on each interim day anyway (i.e., when preschedule day is not day before OD.)  Is this information shared in PIT? What do participants do with interim day information?  How do deficit participants indicate they would like to claim a portion of any voluntary holdback that may be available?

On page 5 in item ii, define/specify what is meant by “information necessary to match surplus Participants with deficit Participants in subregions without a central transmission hub”.  Is this a specific type of file transfer (e.g., PL, PTPL)?  Is this an opportunity to submit information, or is it an obligation?

Also, define/specify ‘subregions without a central transmission hub’.  If this refers only to SWEDE, then state that.

On page 6 in item iii, specify how voluntary holdback is submitted, is it through the PIT or via file transfer? Does it have to be done through PIT or can it be a bilateral trade?

On page 6, specify that “Deficit” participants will notify PTO of amount of holdback needed.

On page 6, describe results that will be posted, will this include which participant(s) you will be paired with, or just volumetric data?

On page 6, specify that “Surplus” participants can exchange holdback. Text states that holdback exchange can occur between 07:00 and 12:00, but Figure 2 (and Design Document) indicates it can occur from 07:00 to T-120.

On page 5, is it “Preschedule” or “Prescheduling” Day? Should be consistent throughout.

Figure 2 is not referenced anywhere in the document.

03 Please supply any comments related to the operating day.

Final forecast data is submitted through SFTP and holdback is exchanged through PIT, correct?

Tariff defines Energy Deployment as “A delivery of energy that a Participant is required to provide during an Operating Day”.  Be concise with the use of the word ‘deploy’ in this section.

Design document mentions that deficit participants shall confirm need for and amount of Energy Deployment to be called upon, but this step is not specifically addressed in the BPM.  Could be included in Figure 2 as well.

Design document indicates tagging must occur by T-60.  BPM indicates T-90.

04 Please supply any comments related to the current format, structure, contents of the business practice - as it relates to a template for all business practices to follow.

Regarding format:

Make sure heading/sub-heading formats are consistent throughout document.

Use consistent format when referring to times, e.g. 06:00 PPT, not 6:00 PPT.

Use consistent font throughout, including for graphics.

Regarding structure:

This BPM contains some vague language, be as specific as possible.

Use consistent writing style throughout all BPMs.

Regarding content:

Leverage wording used in Design Document and ensure that BPM and Design Document are aligned.

General Comment

On page 3 in Purpose section, end of paragraph looks to be cut off.

On page 6, final paragraph in Preschedule section appears to be cut off (or it might be an invisible link to Figure 2).

On page 4, 2nd sentence in 2nd paragraph is cutoff or incomplete.

On page 3 in Uncertainty section, strike ‘as to a Participant’.

Thanks for the opportunity to comment!