01: Please supply any comments related to corrections in the Definitions Section
No response submitted.
02: Please supply any comments on redlines to Tariff section 7 (Credit Requirements and Settlement for Holdback and Delivered Energy)
No response submitted.
03: Please supply any comments related to redlines to Tariff section 10.2 (Treatment of Confidential or Commercially Sensitive Information)
No response submitted.
04: Please supply any comments related to redlines to Tariff sections 14.2.1.2, 16.1.5, and 19.2 (relating to Forward Showing Submittal demonstration of inter- subregional transmission in lieu of Capacity)
No response submitted.
05: Please supply any comments on redlines to Tariff sections 16.1.2.1, 16.1.2.3, and 16.2.5.2.2 (related to corrected "annual LOLE" references to "Seasonal LOLE")
No response submitted.
06: Please supply any comments on redlines to Tariff sections 16.1.2, 16.2.5.4, 20.1.1 (related to options for DR)
In sections 16.1.3 and 16.2.5.4 The method to determine QCC for Demand Response seems to be inaccurate if the resource can be deployed for longer than five hours. For example, as it reads in the draft language now, a 10 MW demand reduction resource that can be deployed for 20 hours would receive 40 MW QCC (10 MW X 20 hours/5). Powerex suggests that in the calculation, the number of hours a resource can demonstrate load reduction be capped at a maximum of five.
07: Please supply any comments on redlines to Tariff section 16.2.7 (relating to Total RA Transfer)
The purpose of RA Transfer was to allow the transfer of RA Forward Showing Capacity Requirement between Participants. Powerex notes that the proposed edits to this section are attempting to address an inconsistency in the original tariff language. However, the proposed edits have the effect of describing an RA Transfer as a transfer of QCC, rather than a transfer of the Forward Showing RA obligation. Powerex suggest the proposed edits be replaced with the following language:
“16.2.7 Total RA Transfer: A Participant may agree with another Participant on a transfer of a portion of their FS Capacity Requirement (“RA Transfer”), provided that the details and duration of such transfer are reported to WPP for validation in accordance with procedures and information requirements specified in the Business Practice Manuals. Where such transfers have been duly reported and validated, an RA Transfer will be added to SUBTRACTED FROM the purchasing Participant’s Portfolio QCC FORWARD SHOWING CAPACITY REQUIREMENT and subtracted from ADDED TO the selling Participant’s Portfolio QCC FORWARD SHOWING CAPACITY REQUIREMENT.”
Powerex further notes that the implementation of RA Transfer may require a review and modification of the Operations Program Sharing Calculation and associated processes.
08: Please supply any comments on redlines to Tariff section 16.2.8 (relating to Planned Outages)
No response submitted.
09: Please supply any comments on redlines to Tariff section 16.3.2 (relating to Transmission Exceptions)
No response submitted.
10: Please supply any comments on redlines to Tariff sections 17.2.7 and 17.2.8 (relating to Forward Showing Deficiency Charge)
No response submitted.
11: Please supply any comments on redlines to Tariff section 19.1 (relating to Operations Program Timeline and Supporting Information
"Forced Outage” is not a defined term in the Tariff, rather the lower case “forced outage” is primarily used (with the possible exception of section 20.1.1 where change in Forced Outages is defined). Consider whether a consistent definition / defined term is worthwhile.
Powerex suggests the language on forced outages be more inclusive to instances where a forced outage is caused by a transmission outage or derate. Removing the phrase “associated with imports” would better align with the change in Forced Outages definition in Section 20.1.1
12: Please supply any comments on redlines to Tariff section 19.4 (relating to Operations Program Timeline and Participant Tx Inputs)
No response submitted.
13: Please supply any comments on redlines to Tariff section 19.5 and 20.4.1.2 (relating to reference correction of Subregions not containing a central transmission hub)
No response submitted.
14: Please supply any comments on redlines to Tariff section 19.5 (relating to decription of mechanics of Voluntary Holdback)
No response submitted.
15: Please supply any comments on redlines to Tariff section 20.1.1 (relating to update to description of Sharing Calculation)
Powerex notes that the Sharing Calculation now includes both a Contingency Reserve Adjustment term, and a Contingency Reserve Obligation term. In order to ensure that Participants can accurately calculate these two terms, it is recommended that the WPP make available a numeric example.
Powerex notes that the Uncertainty Factor definition is included twice.
16: Please supply any comments on redlines to Tariff section 20.1.3 (relating to removal of references to lesser priorities of Energy Deployment)
No response submitted.
17: Please supply any comments on redlines to Tariff section 20.2 (relating to description of mechanics of Holdback Requirement)
No response submitted.
18: Please supply any comments on redlines to Tariff section 20.4.1 (relating to how Energy Deployment occurs on Operation Day)
No response submitted.
19: Please supply any comments on redlines to Tariff section 20.4.1.2 and 21.1.4 (relating to reference corrections)
No response submitted.
20: Please supply any comments on redlines to Tariff sections 20.4.2-20.2.4 (relating to corrections to 85 & 80 minutes before the hour)
No response submitted.
21: Please supply any comments on redlines to Tariff section 20.8.1 (relating to incorrect conflation of "Raise Hand" with Voluntary Holdback)
No response submitted.
22: Please supply any comments on redlines to Tariff section 21.2.4 (relating to updating Energy Declined Settlement price to be the Applicable Real-time Index Price for the hour)
No response submitted.
23: Please supply any comments on redlines to Tariff section 21.2.5 (relating to change to Make Whole Adjustment formula)
No response submitted.
General Comment
The following response is for #23 Tariff section 21.2.5:
Powerex notes that according to the new formula, the Make Whole Adjustment has a minimum value of zero, not a maximum of zero. To reflect this, the language in the paragraph preceding the formula should read “The Make Whole Adjustment has a minimum value of zero and is determined as follows:”.