01: Please supply any comments related to the Introduction, Definitions, or Background sections.
1. BPA suggets WPP enable discussion on the fact that with WRAP implementation, a single tag cut could result in: 1) failure to deliver charges under WRAP; 2) LDs under WSPP; and 3) EIM imbalance charges (currently for participants). WSPP failure to deliver charges compound for 5 years as well. There is lot of accumulation that may need to consideration.
2. BPA suggests consideration of an addition of a section that identifes what is not in scope of the BPM (i.e. the program settlements between participants and WPP).
3. BPA would like to discuss the mechanics and possibly cover it in this BPM or in BPM 209 if necessary how those entities who participate in the CAISO WEIM, when a failure to deliver happens, is there a possibility that they would both pay the WRAP penalty and then also pay for the imbalance energy and additional subsequent CAISO settlements?
4. Paragraph 2: Propose removal or modification of "in line with current bilateral practices" as the transactions aren't really "in line" with bilateral practices and also "current" may be difficult to snap a chalk line and undersatnd what that intent is.
5. Paragraph 2: There have been discussions regarding if WRAP enabling agreements will be needed. BPA would like to discuss and potentially include in this BPM.
6. Missing a "the" in front of Tariff
02: Please supply any comments related to the What Settlement Information is Posted section (3).
1. "Sufficient detail" has been a topic of discussion in the working groups. BPA suggests language to be included that identifies the details of what is required "at minimum." Will this be defined in the Settlements Interface Guide?
03: Please supply any comments related to the How Settlement Information is Accessed section (4).
No response submitted.
04: Please supply any comments related to the Timeline section (5).
1. BPA understands the challenges with calculating the settlements due to the timing of the pricing index data. We are still concerned with the latency impacting credit limit risk for entities due to the potential high cost of the WRAP transactions. Without a way to settle the transactions earlier it could prevent the ability to transact with the CP for a period of time until the credit is paid down.
2. Can WPP identify a way for indicating the 10 business day clock has started? Will there be status updates provided somewhere that we could check the progress of WPP receiving all the necessary inputs? As noted concerning credit risk for delays, BPA is concered there are not ramifications if the 10 business days are not met. Can WPP hold itself accountable here?
3. This paragraph speaks to "accopanying details". BPA notes that the index pricing data is possibly not public information if you have to pay for a subscription to obtain it from those companies. It may good to clarify what is meant by "accompanying."
05: Please supply any comments related to the Timeline - Unavailability of external Input Data section (5.1).
1. Modify language to reflect: If the Applicable Index Price data and/or Hourly Shaping Factor data necessary to calculate settlement for a month (in which there is a Holdback Requirement or Energy Deployment) is not available 60 days after the last day of the settlement month...
2. Are the Applicable Index Price data and/or Hourly Shaping Factor data the only inputs that might be unavailable?
3. BPA is somewhat uncomfortable with leaving it to the future to determine how to handle the use of alternative price indexes. Once the program is live, changing BPMs is not a rapid process. BPA suggests this be explored before binding seasons and the BPM 206 updated as necessary to better reflect a reliable protocol.
06: Please supply any comments related to the Timeline - Changes to Inputs after Settlement Values have been Calculated section (5.2).
1. As discussed in the workgroup the term "material" when referring to differences is not equitable between participants. A threshold/percentage/amount is better used in this context. BPA suggests discussion with the working group and this language modified to reflect something more tangible.
2. BPA would like to see a timeline for this statement added: "Once settlements for the given month have been recalculated a notification will be provided to all Participants."
07: Please supply any comments related to the Dispute Resolution Process section (6).
No response submitted.
General Comment
Thank you for the opportunity to comment.
A general overall request, BPA would like to affirm WPP legal has confirmed nothing in the tarriff or this BPM will inhibit the participants ability to settle via WSPP provisions.