01: Please supply any comments related to the Introduction, Definitions, or Background sections.
No response submitted.
02: Please supply any comments related to the Designation of Confidential or Commercially Sensitive Information Section (3).
No response submitted.
03: Please supply any comments related to the Protection of Confidential or Commercially Sensitive Information Section (4).
No response submitted.
04: Please supply any comments related to the General Exceptions section (4.1).
No response submitted.
05: Please supply any comments related to the Composite or Aggregated Information section (4.2).
No response submitted.
06: Please supply any comments related to the Required Disclosures section (4.3).
No response submitted.
07: Please supply any comments related to the Composite or Aggregated Information section (5).
No response submitted.
08: Please supply any comments related to the Disclosing Entity Review section (5.1).
No response submitted.
09: Please supply any comments related to the Disclosing Entity Appeal section (5.2).
No response submitted.
10: Please supply any comments related to the Objection to Format for Change in Participants section (6).
No response submitted.
11: Please supply any comments related to the RAPC Decision to Release Participant-Specific Information section (7).
No response submitted.
General Comment
Shell Energy North America (US), L.P. ("Shell Energy") appreciates the opportunity to comment. As one of only two non-utility entities serving load in the WRAP region, maintaining confidentiality regarding Shell Energy’s load, resources, contracting practices, prices, load forecasting and position is key, as these constitute trade secrets. As such, Shell Energy believes, as a threshold matter, data submitted to WPP or SPP should be treated confidentially by presumption. That is, there should not be an explicit requirement to mark data as confidential to remain so.
Shell Energy understands there will be cases where information is disclosed to FERC, regulators, or other venues as courts. In these cases, it is reasonable to ask for sufficient notice be sent to the WRAP participant. In addition, should WPP possess confidential WRAP participant data that is subject to disclosure, WPP should endeavor to transmit the data in a confidential manner to the regulator requesting or subpoenaing it. In doing so, WPP must make the confidential nature of the data explicitly known as WPP is obligated to keep certain information confidential pursuant to the WRAPA.
Finally, any aggregation should be at a “high enough” level such that it is not possible to back into participant specifics based upon only lightly aggregated data. As an example, if only a single WRAP participant has a biomass generator, WPP should not disclose there is a biomass generator on outage; instead, this disclosure should be aggregated as a ‘thermal resource on outage’ to sufficiently aggregate and protect the confidential nature of a resource on outage.