01 Please supply any comments related to the multi-day-ahead assessment and release.

Shell Energy understands various information is required from participants for the Program Operator (“PO”) to calculate uncertainty and holdback requirements for WRAP participants.   WPP should recognize required information submitted daily will be unique to each WRAP participant, e.g., for those entities which do not operate their own Balancing Authority, contingency reserve requirements may not be applicable. 

In addition, it is Shell Energy’s understanding the results of the multiday assessment will be indicative in nature and not binding; if so, the Ops program timeline business practice document should explicitly clarify this.  

02 Please supply any comments related to the preschedule day.

As a general matter, the more time WRAP participants have to assess and react to holdback information from the PO the better.  The timelines generally appear workable; however, some flexibility may be required at times with respect to the proposed timelines on the Ops preschedule day.  Over the past few years, the bilateral markets at Mid-C and Paloverde have trended to trading on exchanges later than in previous years.  Therefore, it may be imprecise for a participant to assess the volume of holdback to request from surplus WRAP members until the markets begin to frame up—some days this happens as late as 7AM PPT (or later).   In other words, it may be difficult for participants to determine if deficiencies can be addressed in-market such that commitment to holdback is required before significant market activity commences. 

It appears the last sentence of the Preschedule Day paragraph on Pg. 6 is not complete.  

03 Please supply any comments related to the operating day.

Shell Energy recommends the following changes for clarity; it is unclear what is meant by holdback exchange if actual e-tagging occurs later.

Participants are required to provide their final forecast data and complete any holdback exchange at least 120 minutes before the operating hour. The PO will use this data to perform a final execution of the Sharing Calculation, which will be completed at least 105 minutes prior to the operating hour. The results of the Sharing Calculation on the OD are intended to help Participant’s decision-making on the amount of energy to deploy. However, the calculation is indicative because the deficit Participant can claim up to the amount of holdback that they were allocated on the Preschedule Day. Participants must [should endeavor to] tag their Energy Deployments at least 90 minutes before the operating hour.

In addition, the document should discuss situations when energy deployments are E-tagged after T-90.  Would this result in a delivery failure?  The T-90 requirement for E-tagging is quite conservative; tagging activity as late as T-45 to T-20 is observed in markets today.   Shell Energy would recommend setting the soft deadline for E-tagging to T-90 with a hard deadline of T-30.

04 Please supply any comments related to the current format, structure, contents of the business practice - as it relates to a template for all business practices to follow.

The format and contents of the business practice are satisfactory.  WPP could implement changes to accommodate comment submission by creating a downloadable comment template rather than text boxes on the webpage.   

General Comment

Shell Energy North America (US), L.P. ("Shell Energy") appreciates the opportunity to submit comments on the Ops program timeline and appreciates the time commitment of all who contributed to developing it.