01: Please supply any comments related to the Introduction, Definitions, or Background sections.
SRP recommends correcting the term “appraised” to “apprised” to enhance the sentences accuracy and better convey the intent to keep participants informed.
Correction: “to keep Participants and other interested entities apprised regarding the WRAP...”
02: Please supply any comments related to the Designation of Confidential or Commercially Sensitive Information Section (3).
In the phrase “should be cleared marked,” SRP suggests correcting “cleared” to “clearly.”
Correction: “the confidential or commercially sensitive information included on each page should be clearly marked.”
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).
SRP recommends this section be revised to specify that the WPP will notify any affected disclosing Participant(s) within a maximum of five (5) business days after the WPP is notified by FERC of a request for disclosure or a decision to disclose confidential or commercially sensitive information. This amendment has the potential to provide a clear and predictable timeframe, which can improve transparency.
07: Please supply any comments related to the Composite or Aggregated Information section (5).
SRP requests that the BPM explicitly requires the WPP to notify Participants whenever composite or aggregated information is released, including detail of the recipients. This has the potential to ensure all parties are informed and have the ability to monitor the use of data obtained from their information.
08: Please supply any comments related to the Disclosing Entity Review section (5.1).
SRP requests this section be amended to allow Participants to opt-out from the aggregation process. This change would allow participants to withdraw consent to the use of their data in aggregate reports and potentially provide them with the option to better control their confidential information.
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
SRP is encouraged by the WPP’s ongoing efforts in the developing of WRAP BPMs and has provided comments on relevant sections within this BPM.
Further, SRP requests the WPP establish a standardized receipt of acknowledgement process to be uniformly applied across all relevant sections of BPM 402. The process should mandate that the WPP acknowledges receipt of any documents or communications from participants within a specified timeframe, detailing the content received and the date of the receipt. This acknowledgement should be in a form that is verifiable and can be archived and referenced.