Thank you for the opportunity to provide comments on 2025-NTFP-03 related to Planned Outage Edits. We understand this change is to provide clarity on existing policy rather than changing existing policy. APS recommends the following edits to the language presented in blue below:
If the planned outage of a resource was submitted in the FS Submittal, then:
- Resources
that do not qualify for under- or over-performance in the Sharing Calculation due to a planned outage: ROR, Wind, and Solar resources resource forecasts must be entered as zero MW in the ROR, Wind, and Solar data in the input files. - Resources
that do not qualify for Forced Outage in the Sharing Calculation due to a planned outage: Thermal, Storage Hydro, and Energy Storage Resources must be entered as zero Forced Outage MWs in the Thermal, Storage Hydro, and Energy Storage Resources data in the input files.
If the planned outage of a resource was NOT submitted in the FS Submittal, then:
- Resources
that do not qualify for under- or over-performance in the Sharing Calculation due to a planned outage: ROR, Wind, and Solar resources resource forecasts must be entered as the QCC value of the resource in the ROR, Wind, and Solar data in the input files. - Resources
that do not qualify for Forced Outage in the Sharing Calculation due to a planned outage: Thermal, Storage Hydro, and Energy Storage Resources must be entered as zero Forced Outage MWs in the Thermal, Storage Hydro, and Energy Storage Resources in the input files.
“Planned outages MW amounts will not be included in the Forced Outages hourly data submitted in the Operations Program. Furthermore, if a planned outage that was included in the FS Submittal ends earlier in the month than expected and the resource becomes available, the Participant shall not include any Forced Outages MWs for that resource in the Operations Program.”
On the portion of language above, what happens if a planned outage starts early? Is the outage submitted in the Forward Showing on a monthly or daily basis? Meaning, is what is needed when a planned outage starts early, only applicable if an outage starts in a different month or is it if it starts on an earlier day in the same month? Lastly, how should we communicate the forced outage MW for this scenario of a planned outage starting early, does it depend if it was a schedule adjustment vs a forced outage that continues until the start of the planned outage?