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. In addition, there are proposed edits to Appendix E – Planned Outages Attestation that more closely aligns with the requirements of Tariff Section 16.8.2.
101. Please supply any comments related to the changes in BPM 108: Section Planned Outages 3.1.5.2 (pg. 14)202. Please supply any comments related to the changes in BPM 108: Appendix E - Planned Outages Attestation (pg. 21)3General Comment
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Lead Sponsor's Description of the 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. In addition, there are proposed edits to Appendix E – Planned Outages Attestation that more closely aligns with the requirements of Tariff Section 16.8.2.
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Matt H. / BPA
Bonneville appreciates the opportunity to provide comments.