BPM 105 Qualifying Resources
o Section 3.4.3.1 Thermal Resources and Long Duration Storage – includes edits to change the timeframe around the annual Operational demonstration period, changing it from the current ’12-Month period prior to the FS Submittal due date’ to ’16-Month period prior to the end of the Cure Period’ -- we support the clarifying language, would even suggest it should be modified further so that the period doesn’t run all the way to the due date of the FS submittal. It is impossible for actual operational data that runs all the way through the day the submittal is due to be reviewed by a senior officials, an attestation of that data to be signed and still meet the submittal date/time at 5:00 PPT, when the period doesn't end until midnight on that same day. As a result, participants have to cut the demonstration period short for submittal, review, and attestation purposes only to redo the same work again during the Cure Period, to include the complete set of data. As proposed moving to the 16 months before the end of the Cure Period, results in the same issue in collection of data. It would make more sense for this change to something like the 12-month period ending 30 days prior to the Forward Showing Submittal deadline.
o Sections 3.4.3.2 Storage Hydro Resources – includes the same language ’12-Month period prior to the FS Submittal due date’ as in Section 3.4.3.1 (in multiple places) – why is this definition changing in one section and not being applied uniformly in all places with the same 12-Month period? See previous comment on section 3.4.3.1 for additional thoughts
o Section 3.4.3.3 ESRs, Section 3.4.3.4, Section 3.4.3.5, and Section 3.4.3.6 -- All of these sections are Operational tests, but they do not include a period requirement like in Sections 3.4.3.1 and 3.4.3.2 shouldn’t this same period requirement be included for all Operational Tests?