COMMENT FOR BPM 107 - Forward Showing Deficiency Charge

Submitted Jan. 31, 2024, 1:50 p.m.





01: Please supply any comments related to the Introduction, Definitions, or Background sections.

No response submitted.

02: Please supply any comments related to the Calculating the Deficiency Charge section (3).

No response submitted.

03: Please supply any comments related to the Calculating the Deficiency Charge - Calculating the Deficiency section (3.1).

No response submitted.

04: Please supply any comments related to the Calculating the Deficiency Charge - Calculating the Deficiency Charge section (3.2).

SRP recognizes the thoroughness in detailing the methodology for Calculating the Deficiency Charge and appreciates the WPPs efforts to provide detailed guidelines. However, to enhance clarity for all participants, SRP suggests the inclusion of examples within this section. The addition of examples may assist participants in better understanding and applying these complex calculations.

05: Please supply any comments related to the Calculating the Deficiency Charge - Determining Certain Components of the Deficiency Charge Calculation section (3.3).

No response submitted.

06: Please supply any comments related to the Timing of Deficiency Charge Revenue Collection section (4).

No response submitted.

07: Please supply any comments to the Allocation of Revenues from Deficiency Charges section (5).

No response submitted.

08: Please supply any comments related to the Board Appeal Process section (6).

SRP appreciates the outlined Board Appeal Process. SRP recommends including guidelines on the criteria for appeal consideration. This may help participants have a clear understanding on the grounds which appeals can be made. Further, SRP suggest adding clear directions or a direct link to the appeal form on the WPP website within the BPM, making it more accessible and easier to locate.

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.