01 Please supply any comments related to the Introduction, Definitions, or Background sections.
No response submitted.
02 Please supply any comments related to the Applicable Index Prices section.
No response submitted.
03 Please supply any comments related to the Settlement Pricing Overview and Components introduction section.
Powerex suggests that the “Energy Declined Settlement Price” be renamed, to be more inclusive of its application to settle energy deployed quantities as well.
04 Please supply any comments related to the Settlement Pricing Overview and Components - Total Settlement Price section.
Powerex suggests this sentence be removed, since the Make Whole section of the BPM addresses the declined energy credits. Having it alongside the settlement math for negative sharing participants creates confusion. “A Participant that declines energy that would have been provided under a Holdback Requirement shall be credited the Energy Declined Settlement Price times the MWh of energy declined by such Participant.”
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.
No response submitted.
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.
No response submitted.
08 Please supply any comments related to the Settlement Pricing Overview and Components - Make Whole Adjustment section.
Powerex agrees with the settlement mechanism proposed in the BPM to allocate Make Whole to multiple buyers. We believe that an example with sample prices and energy volumes would help participants understand how the cost is allocated across multiple buyers. To keep the section clear and succinct, this example could be in an appendix at the end of the BPM. The existing language in this section can be rewritten to be clearer on how the settlement is implemented, while referencing the appendix for the example calculation.
09 Please supply any comments related to the Settlement Pricing Overview and Components - Allocation of Holdback Settlement to Multiple Participants section.
No response submitted.
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.
No response submitted.
General Comment
Powerex believes the BPM would benefit from expanding the Definitions section 1.4 and listing all capitalized terms. This would provide participants with a useful reference for the energy components and prices used in the settlement process.