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) .
No response submitted.
03: Please supply any comments related to the Calculation of Delivery Failure Charge section (4).
SRP values the detailed approach to calculating the Delivery Failure Charge and recommends the inclusion of various examples demonstrating charge calculations, particularly in unusual market conditions such as negative pricing.
Further, clarification would be appreciated on the method used when both Day-Ahead and Real-Time Prices are negative. SRP's understanding is that using historical positive values may not accurately represent current market conditions. A review of this approach is suggested to ensure fairness and market relevance.
SRP request detailed information on the Cumulative Delivery Failure Window, particularly its duration and alignment with the 5-year forward showing period, and how delivery failures are tracked within this rolling timeframe.
Further explanation is encouraged regarding the rationale behind the Delivery Failure Factors, both in standard situations and when other participants cover a shortfall. This will help ensure that the penalty structure is perceived as fair and reasonable.
04: Please supply any comments related to the Dollar Limit on Delivery Failure Charges During a Forward Showing Year section (5).
SRP recommends the WPP provide examples illustrating the calculation of the cap on Delivery Failure Charges. Clear examples would help stakeholders comprehend how this cap operates in practice, especially when compared to anticipated charges in forward planning periods.
Additionally, SRP requests clarification on whether there's a definitive limit to Delivery Failure Charges. This may help participants' financial planning and risk management strategies.
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).
SRP appreciates the outline of the waiver process. To further assist stakeholders, SRP recommends adding clear directions or a direct link to the wavier form on the WPP website within the BPM, making it more accessible and easier to locate.
Lastly, SRP request the WPP clarify if the valid wavier justification examples are intended to require participants to experience situations as severe as EEA3.
07: Please supply any comments related to the Possible Expulsion for Repeated Energy Delivery Failures section (8).
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.