Request Summary
Clarifies deliverability of resources/contracts in BPM 108 Appendix A – FS Demonstration Attestation
Co-sponsors
Description Of Issue
Some Participants have interpreted the language in BPM 108 Appendix A - FS Demonstration Attestation to mean they are attesting to meeting the applicable Season’s Monthly FS Capacity Requirements and FS Transmission Requirements. The intent of the attestation was a declaration that the resources and contracts in the FS could be used to interchangeably serve any of the loads in the same FS (i.e. “deliverability”).
Proposed Solution
Edit the language in BPM 108 Appendix A – FS Demonstration Attestation to clarify the intent of a declaration of deliverability rather than a testament to meeting the FS Capacity Requirements and FS Transmission Requirements.
Specific Document And Language
BPM 108 FS Submittal Process
Appendix A – FS Demonstration Attestation
I, the undersigned, who, as [title], serves as a senior official of [Participant], hereby attest that I have reviewed [Participant]’s FS Submittal provided this day by [Participant] to Western Power Pool, and that the statements therein are true, correct and complete to the best of my knowledge and belief following due inquiry appropriate to the reliability and resource adequacy matters addressed therein. I further attest that, to the best of my knowledge and belief following due inquiry, the loads in the FS Demonstration made in such FS Submittal can be served by the Qualifying Resources and Net Contract QCC in such FS Demonstration.
Suggested Language Update
BPM 108 FS Submittal Process
Appendix A – FS Demonstration Attestation
I, the undersigned, who, as [title], serves as a senior official of [Participant], hereby attest that I have reviewed [Participant]’s FS Submittal provided this day by [Participant] to Western Power Pool, and that the statements therein are true, correct and complete to the best of my knowledge and belief following due inquiry appropriate to the reliability and resource adequacy matters addressed therein. I further attest that, to the best of my knowledge and belief following due inquiry, the loads in the FS Demonstration made in such FS Submittal can be served by the Qualifying Resources and Net Contract QCC in such FS Demonstration the output of the Qualifying Resources and Qualifying Contracts in the FS Submittal can be used to serve and are deliverable to the loads in such FS Submittal.
Benefits
The attestation is necessary for Participants to declare their due diligence in providing best available information, as well as verifying that the capacity and transmission provided on a single FS Submittal can be utilized to serve the load in that FS Submittal (as opposed to providing multiple FS Submittals for pockets of load and associated resources when resources are not available to all of the Participant's loads).
Data Or Information