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

Central Hub, Holdback Capacity, Voluntary Holdback and Uncertainty Factor reference BPM's 204 & 203 which are not yet released for us to review definition. How do we know what these are?

02: Please supply any comments related to the Reduction in Sharing Calculation section.

No response submitted.

03: Please supply any comments related to the Priorities of Access During the Transition Period When Aggregate Holdback Requirements Are Limited section.

"For any Sharing Event during the Transition Period when there is insufficient holdback" - this should be hold back an voluntary offered capacity?

Program design in (Ops trials) have described that Voluntary holdback is assigned first and then positive sharing result holdback second.  Shouldn’t the Transition period be operating in this same fashion?  The way this document is written currently it leads you to believe that tiers apply first to positive sharing holdback, and then to voluntary offered..  I think a clarification of what holdback is needed.. Holdback = positive sharing plus voluntary offered……. And that may ultimately end up in definition in BPM 204 but we don’t have it with this BPM so it needs to be clear and called out.

 

 

05: Please supply any comments related to the Access to Voluntarily Offered Capacity section.

"Voluntary Holdback based on the Priority Tiers of the Participants needing assistance in any case where the needed assistance is less than the available voluntary assistance. "

It really doesn’t matter if it is voluntary offered or positive sharing holdback - assistance is granted on a single set of Priority Tiers.

Consider rewriting the sections to describe access to 'Holdback' any and all that is available as a single pool, that gets allocated by Priority Tier. 

 

 

It really doesn’t matter if it is voluntary offered or positive sharing holdback - assistance is granted on a single set of Priority Tiers.

Consider rewriting the sections to describe access to 'Holdback' any and all that is available as a single pool, that gets allocated by Priority Tier. 

General Comment

Please see BPA comments attached