01: Please supply any comments related to the final paragraph of the Non-Exclusive List of Potential Waiver Justifications section (7.3) - text in RED.
No response submitted.
02: Please supply any comments related to the Presumptive Waiver for Uncertainty Exceedances section (7.4) - text in RED.
PacifiCorp appreciates the additional language which more clearly details the priority with which Participants are expected to view WRAP holdback deliveries.
03: Please supply any additional comments on this BPM.
PacifiCorp is uncomfortable with the outcome for Participants who are expecting to receive Holdback from another Participant, but do not receive it due to a waived non-delivery event.
If the non-delivering Participant receives a waiver, the original intended recipient of the holdback receives nothing – neither MW’s nor financial compensation. This outcome is less desirable than WSPP Schedule C, where liquidated damages are paid in the event of non-delivery. PacifiCorp would suggest the Participant who experienced non delivery receive some amount of compensation, such as 2X the applicable hourly index for the volume of energy not received.
General Comment
PacifiCorp looks forward to further details from the WRAP regarding e-tagging expectations of its holdback product. This BPM originally included a fourth item under section 3 (omitted from this version), requiring the non-delivering entity to ensure that the e-tag energy profile reflected the non-delivery.
Standard industry practice dictates e-tags are created by recipients of scheduled energy. If this practice is carried over into the WRAP, in the event a Participant cannot deliver its holdback obligation, it would be incumbent upon the recipient of holdback to reduce the tagged energy schedule to reflect non-delivery. PacifiCorp would like to receive additional guidance on how WRAP would handle an outcome in which a Participant provides notice of non-delivery, but the recipient does not reduce the e-tag energy schedule (and thus receives the energy anyway).