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

• Introduction, 1 paragraph, last sentence: May want to add a sentence stating something like: The program fully expects to revise this BP in coordination with the emergence of organized markets affecting its members. Also to that point: Probably a good idea to keep this BP as a draft until organized markets settlement structures are finalized. 
• Definitions:
  • DA Applicable Index Price: DA ICE index likely to become even more illiquid with emergence of organized DA markets.   Will likely need to change this Index
  • Holdback Settlement Price: It’s not obvious how the daily index figures into these statements since the Declined Settlement Price uses the RT index.
  • Energy Declined Settlement Price: Terminology creates confusion.  If deployed/undeployed energy terms are used in the settlement calculation, and they are assigned the same price, maybe state these are priced the same to avoid confusion. It’s difficult to understand this statement of value without understanding the definitions above.  For example, why “lessor”?  If RT is multiple times the price of DA, why would I want to be limited in my compensation for energy deployment?  I’m probably not understanding the logic here.
• Background, 1st paragraph, 2nd sentence: It might be helpful to identify the parties as “Participant 1” and “Participant 2” so it is easier for the reader to keep track of who is doing what.

02 Please supply any comments related to the Applicable Index Prices section.

• Applicable Index Prices: The important issue here is assuring a process/mechanism to allow for future changes to this BPM’s chosen Index Prices.  Even more so to sync with the future market landscape (CAISO/SPP M+/Other)
• NW Subregion: This will likely need to change prior to the first binding season.

03 Please supply any comments related to the Settlement Pricing Overview and Components introduction section.

• 'The Price for Energy Deployments is known as the Energy Declined Settlement Price.' - This should be in the definitions. For the first-time reader, this language is unintuitive.
• 1st paragraph, last sentence + 2nd paragraph - Seems to have some redundancy

04 Please supply any comments related to the Settlement Pricing Overview and Components - Total Settlement Price section.

• System Marginal Energy Cost - Might be extra clear here that we are not using the LMP, but rather only the energy component.  Are there any circumstances where the SMEC is not universal footprint wide?

05 Please supply any comments related to the Settlement Pricing Overview and Components - Holdback Settlement Price section.

No Comment

06 Please supply any comments related to the Settlement Pricing Overview and Components – Energy Declined Settlement Price section.

• 'Lesser' - See related comment above

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.

2nd paragraph, 'Negative Sharing Requirement' - What does this mean “negative” sharing requirement Should be defined above?  It’s difficult to understand the rest of this paragraph without more context.
This should be in definitions. 

08 Please supply any comments related to the Settlement Pricing Overview and Components - Make Whole Adjustment section.

• Is this computed on an hourly basis or is it only applicable for certain fixed blocks of time (such as heavy load hours as defined by WECC)? The concept of Capacity Critical hours should be in this BP.
• 'Make Whole Adjustment (when applicable) = How is 'when possible' defined?  Is it ‘automatically’ tracked or does the selling entity need to take action? Need to explain when it is applicable.
• Real-time Value of Unheld Energy = (Maximum Holdback MW in Block  – Holdback MW Requested) × Real-Time Applicable Index Price - Clarify if 'Block' refers to the time blocki in question.
• 'Possible Block Sale Revenue' - 
  • Wording conveys uncertainty.  Should this be described as “Allowed” or…??
  • How is this going to be computed and who is going to make this calculation?
  • Maybe opp cost of basic DA sale?  Consideration for geographic price basis opp cost? Eg, did BPA give up a COB or NOB sale but was compensated at a lower MidC price?
  • 'Final Settlement Revenue' - New term?
  • 'Unheld Energy' - This is a new term? Need definitions

09 Please supply any comments related to the Settlement Pricing Overview and Components - Allocation of Holdback Settlement to Multiple Participants section.

No Comment

10 Please supply any comments related to the Settlement Pricing Overview and Components - Transmission Service section.

No Comment

11 Please supply any comments related to the Settlement Pricing Overview and Components - Settlement Pricing for Subregions section.

• 'Unheld Energy' - New term, need defined
• 1st pragraph, last sentence - Does this mean that the Participant who was deficit has to pay based on the price index to which the holdback or Energy Deployment was delivered?  It would seem that would need to be the case in order to make sure that there is enough revenue to pay both the Participant who is supplying the energy/holdback and the Participant who provided the transmission.  Another simple way to deal with this is to say that the receiving party pays the sum of these two.
• Same area as above - To compute this transmission payment the BMP needs to clearly specify if this difference is computed as source minus sink or sink minus source.

General Comment

Please see comments attached.