Request Summary
Clarifies requirements on planned outage reporting and attestation
Co-sponsors
Description Of Issue
The language in BPM 108 can be interpreted to mean a Participant can provide data in their FS Submittal regarding planned outages in lieu of submitting Appendix E – Planned Outages Attestation. Given that planned outages can change, the original intent was to require all Participants to submit BPM 108 Appendix E – Planned Outages Attestation stating the sum of expected planned outages at any one time during the Binding Season will be equal to or less than the surplus stated in its FS Demonstration at that time.
Proposed Solution
Edit the language in BPM 108 Section 3.1.5.2. Planned Outages not underway at the time of the FS Submittal [pages 14-15] to clarify the intent of reporting planned outages in the FS Submittal and to clarify that submission of Appendix E – Planned Outage Attestation is required, not optional.
Specific Document And Language
BPM 108 FS Submittal Process
3.1.5.2. Planned Outages not underway at the time of the FS Submittal [pages 14-15]
Participants have the discretion to take planned outages at any time during the Binding Season, but are required to take planned outages out of their surplus FS Demonstration capacity or to procure additional supply to replace such capacity on outage Appendix E – Planned Outages Attestation.
Participants may provide information on Qualifying Resources that are planned to be out of service during the Binding Season as part of their FS Submittal, but if such data cannot be supplied with reasonable certainty (i.e. if such planned outages may be subject to change), a Participant may provide a Senior Official Attestation (found in Appendix E – Planned Outages Attestation) by the FS Deadline that the sum of expected planned outages at any one time during the Binding Season will be equal to or less than the surplus stated in its FS Demonstration at that time.
Participants are expected to procure the necessary capacity or energy to meet the Operations Program requirements regardless of planned outage schedules. A planned outage shall not justify a waiver of, or exception to, a Participant’s Holdback Requirement or Energy Deployment obligations.
Suggested Language Update
BPM 108 FS Submittal Process
3.1.5.2. Planned Outages not underway at the time of the FS Submittal [pages 14-15]
Participants have the discretion to take planned outages at any time during the Binding Season, but are required to take planned outages out of their surplus FS Demonstration capacity or to procure additional supply to replace such capacity on outage Appendix E – Planned Outages Attestation.
Participants may provide information on Qualifying Resources that are planned to be out of service during the Binding Season as part of their FS Submittal to ensure QCC from those resources is not utilized to meet a monthly FS Capacity Requirement during the planned outage. Capacity associated with such resources shall be deducted from the FS Demonstration for such month(s).
but if such data cannot be supplied with reasonable certainty (i.e. if such planned outages may be subject to change), a Each Participant may shall provide a Senior Official Attestation (found in Appendix E – Planned Outages Attestation) by the FS Deadline that the sum of expected planned outages at any one time during the Binding Season will be equal to or less than the surplus stated in its FS Demonstration at that time.
Participants are expected to procure the necessary capacity or energy to meet the Operations Program requirements regardless of planned outage schedules. A planned outage shall not justify a waiver of, or exception to, a Participant’s Holdback Requirement or Energy Deployment obligations.
Benefits
Submission of the BPM 108 Appendix E – Planned Outages Attestation is required to provide WPP with Participant acknowledgment that the taking of planned outages during a Binding Season is at the risk of that Participant. Participants are expected to backfill any capacity on planned outage during a Binding Season either by purchasing additional capacity or energy, or by having surplus capacity prior to taking the planned outage.
Data Or Information
Implementation would be an immediate republishing of BPM 108 and using that updated version for the Forward Showing immediately following Board approval of this proposal.