01 Please supply any comments related to the Introduction, Definitions, or Background sections.
Unheld Energy and Declined Energy are undefined in this document, and definitions are not included in the Design Document or the Tariff.
02 Please supply any comments related to the Applicable Index Prices section.
PAC would appreciate more flexible language in this section which considers possible changes in nature and number of program subregions due to program membership change as well as DA market implementations.
03 Please supply any comments related to the Settlement Pricing Overview and Components introduction section.
No response submitted.
04 Please supply any comments related to the Settlement Pricing Overview and Components - Total Settlement Price section.
This section includes use of a CAISO price index for calculating the Total Settlement Price, however, a specific CAISO index is not determined in this document. PAC would appreciate further specificity. PAC will look to BPM 207 (Settlement Process), once published, to also include definitive details regarding which CAISO index to utilize for settlement. It may also be worth designating a backup index, should the primary index not be available.
05 Please supply any comments related to the Settlement Pricing Overview and Components - Holdback Settlement Price section.
No response submitted.
06 Please supply any comments related to the Settlement Pricing Overview and Components – Energy Declined Settlement Price section.
"Declined Energy" is not defined in this document, the WRAP design document or the WRAP tariff.
"Energy Declined Settlement Price" is a somewhat confusing term, as in some cases it is used when calculating settlement for energy that was deployed, not declined.
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.
An example would be appreciated in this section, as is provided in section 4.6.
08 Please supply any comments related to the Settlement Pricing Overview and Components - Make Whole Adjustment section.
'Unheld Energy' is not defined in this document, the WRAP design document or the WRAP tariff.
09 Please supply any comments related to the Settlement Pricing Overview and Components - Allocation of Holdback Settlement to Multiple Participants section.
Typo in final paragraph. "Participant"
10 Please supply any comments related to the Settlement Pricing Overview and Components - Transmission Service section.
No response submitted.
11 Please supply any comments related to the Settlement Pricing Overview and Components - Settlement Pricing for Subregions section.
Where seller and buyer are located in different subregions, the wording could be more clear to state the highest of the subregions' indices will be applicable to calculated settlements.
General Comment
PAC appreciates the opportunity to comment on this BPM.