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

No response submitted.

02: Please supply any comments related to the Notification of Anticipated Delivery Failure section (3) .

3.  Notification of Anticipated Delivery Failure

                4.  Ensure the energy profile on the E-Tag for the intended delivery accurately reflects the expected non-delivery.

This will need to be completed by the deficit entity, as they’re the buyer, and the only ones able to change the E-Tag.  Does the BPM need to clarify this point?

03: Please supply any comments related to the Calculation of Delivery Failure Charge section (4).

4.  Calculation of Delivery Failure Charge

Per the BPM: “Energy Delivery Failures occurring in multiple hours on the same Day are counted as one Energy Delivery Failure for purposes of calculating the Delivery Failure Charges.” Does the counter ever re-set? 

Examples

Entity A has one failure to deliver in July and another in August (same binding season) is the August failure considered the second, or does the counter reset monthly like the FS Monthly Deficiency Charge?

Entity A has a failure to deliver in July 2026, and a second failure in January 2027.  Does the counter reset as WRAP has entered a new binding season.

Entity A has a failure to deliver in July 2026, and a second failure in December 2029.  Does the counter never reset, and failure counts are per entity into perpetuity?

04: Please supply any comments related to the Dollar Limit on Delivery Failure Charges During a Forward Showing Year section (5).

No response submitted.

05: Please supply any comments related to the Allocation of Revenues from Payment of Delivery Failure Charges section (6).

No response submitted.

06: Please supply any comments related to the Waiver of an Energy Deployment Obligation section (7).

No response submitted.

07: Please supply any comments related to the Possible Expulsion for Repeated Energy Delivery Failures section (8).

No response submitted.

General Comment

PNM appreciates the opportunity to comment.