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

The format and detail in this BPM are at a really good level. It would allow someone with little knowledge of the WRAP program to be able to understand the OPS Transition Period.

02: Please supply any comments related to the Reduction in Sharing Calculation section.

This section could benefit from an example, so it is easier to follow/understand. For example, this verbiage is full of information but hard for a person with no FS knowledge to understand this in the OPS program:

“any Participant that was found under the Forward Showing Program to have a Monthly Capacity Deficiency shall be reduced by the MW quantity of such Monthly Capacity Deficiency, but only if the Participant paid an Forward Showing (FS) Deficiency Charge for such Monthly Capacity Deficiency”

03: Please supply any comments related to the Priorities of Access During the Transition Period When Aggregate Holdback Requirements Are Limited section.

Holdback and Voluntary Holdback need to be more clearly defined. This BPM seems to in contrast with how Structured Testing is being taught regarding Voluntary Holdback priority with a positive sharing calculation.

A positive sharing calculation is verified by the FS data that is loaded into the OPS client tool. How is Voluntary Holdback verified for a surplus entity since this surplus is considered above and beyond the Sharing Calculation result?

Which takes priority? VH or Surplus Sharing Calculation result? Which is allotted first to WRAP?

05: Please supply any comments related to the Access to Voluntarily Offered Capacity section.

No comment

General Comment

This BPM refers to a few other BPMs that are not available yet, so it was hard to make comments on the terms and definitions involving BPMs 204 & 203

Uncertainty

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