01 Please supply any comments related to the Introduction, Definitions, or Background sections.
In the definition of “Hourly Shaping Factor”, the term “relevant season” needs some clarity around the specific dates of the Winter and Summer season.
With the pricing being dictated by the WRAP Tariff and calculated by the Program Administrator, what happens if pricing is delayed due to the availability of the published index prices? How will entities deal with credit exposures?
“The WRAP Tariff thus provides for calculation of separate prices to compensate for Holdback Requirement and Energy Deployment, along with separate calculations of i) the amount to be paid and received as compensation for Holdback Requirement; and ii) the amount to be paid and received as compensation for Energy Deployment.”
Would it be possible for an entity to be compensated for both the Holdback and Energy Deployment or just one or the other?
02 Please supply any comments related to the Applicable Index Prices section.
Regarding the Northwest Subregion:
“The Day-Ahead Applicable Index Price is the ICE Day-Ahead (DA) Mid-Columbia (Mid-C) Index.”
Where will this be posted for verification? What happens when there are discrepancies?
“The Real-Time Applicable Index Price is the Powerdex real-time Mid-Columbia Index.”
What happens when the RT Index price is not available? Historically, Powerdex can be 10-15 days late.
03 Please supply any comments related to the Settlement Pricing Overview and Components introduction section.
This section could benefit from actual examples, so the verbiage is easier to follow and understand.
04 Please supply any comments related to the Settlement Pricing Overview and Components - Total Settlement Price section.
It would benefit the reader to provide specific examples of how the charges are calculated for deficient Participants.
Hourly Shaping Factor: Can you provide an example calculation illustrating the BPM verbiage?
Regarding the System Marginal Energy Cost (“SMEC”): How are price adjustments handled if CAISO republishes the SMEC price? Will the settlement calculations get adjusted? How does this work? Can you please provide an example for clarity?
05 Please supply any comments related to the Settlement Pricing Overview and Components - Holdback Settlement Price section.
This section could benefit from some examples of what this would look like.
06 Please supply any comments related to the Settlement Pricing Overview and Components – Energy Declined Settlement Price section.
This section could benefit from some examples of what this would look like.
07 Please supply any comments related to the Settlement Pricing Overview and Components - Application of Pricing and Quantities for Holdback Requirements and Energy Deployment Transactions section.
Question/Comment: “A Participant that provides energy to another Participant pursuant to an Energy Deployment shall be paid the Energy Declined Settlement Price times the MWhs of energy provided to such other Participant, and its total payments shall be reduced by the Energy Declined Settlement Price times the MWhs of energy that would have been provided under a Holdback Requirement but were declined by the other Participant.”
Is this saying that a Participant isn’t paid for an energy deployment if the deployment is declined? Please clarify.
This is quite hard to understand. This verbiage could benefit from an example of the calculation
Also, “A Participant that declines energy that would have been provided under a Holdback Requirement shall be credited the Energy Declined Settlement Price times the MWhs of energy declined by such Participant.
Does this mean that the Participant is charged for the deployment? It isn't easy to understand the way it’s written. How can they be credited an amount if they weren’t charged for it? This could benefit from an example and the Surplus Participant and Deficit Participant clearly labeled throughout the BPM.
08 Please supply any comments related to the Settlement Pricing Overview and Components - Make Whole Adjustment section.
This section could benefit from some examples of what this would look like.
09 Please supply any comments related to the Settlement Pricing Overview and Components - Allocation of Holdback Settlement to Multiple Participants section.
This section could benefit from some examples of what this would look like.
10 Please supply any comments related to the Settlement Pricing Overview and Components - Transmission Service section.
How would a Participant that supplied transmission in the same subregion be compensated or recognized by the program as being a Surplus Participant that Held Back firm transmission service to serve the WRAP program?
11 Please supply any comments related to the Settlement Pricing Overview and Components - Settlement Pricing for Subregions section.
Program Administrator and Program Operator Roles: The PA will be responsible for calculating and posting settlement quantities and prices in accordance with the WRAP Tariff.
Is this information available for everyone to see, or only those associated with your transactions?
Transaction Components Provided:
Specifically, the PA will calculate and provide to each selling and purchasing Participant in the Holdback Requirement or Energy Deployment transaction with the following quantities and values, as applicable to each of the two types of transactions: How would disputes be addressed when it is applicable?
Timing
Will Participants have to agree on the transaction data before submitting it to the PA? How will transactions be recorded?
General Comment
Overall, this document could benefit from labeling the Participant in the examples provided as either the Surplus or Deficit Participant.
Question: Curious how the BPM might change with DA market implemenation? Is there an opportunity to change a BPM once its been approved by the board?
Also, providing examples with screenshots from the WRAP OPS Client tool to articulate the many calculations listed in BPM 206 could aid in helping the reader visually understand the various calculations listed in the BPM. It would also provide clarity to the reader regardless of their level of understanding of the WRAP program.
Seattle appreciates the opportunity to comment on BPM 206. Thank you!