1. 6.0:  Missing a word in the last sentence:  "needed to meet the reliability metric each month will then be converted to unforced capacity (UCAP) values (see Section 9) to calculate the FSPRMs (as a percentage)."

2.  6.1:  The description of EFORd for Thermals does NOT correspond to the EFOFcch description used in BPM 105 (section 4.2). BPM 105 describes using 6 years of data, and removing the worst year.  Concern of why would we utilize a totally different methodology and philosophy in the calculation of EFORd? It seems that dropping the worst year of 6 in one type of calculation is valid, but why would it not be valid in the other? Consistency is important here.

Table 2 of the BPM also calls out the use of Thermal QCC as defined in BPM105, again causing an inconsistancy.

3.  6.3:  Appears there may be a contradiction or there may need to be some clarification.  “ Wind resources will be modeled together as a single wind resource per LRZ in the LOLE Study.” Vs Page 12 “Actual resource output will be used when available.”    (assume actual resource data is included in the LRZ study?)

4.  6.4:  Section is on solar resources, but appears maybe a copy/paste error as this indicates wind "The PO will identify in the Study scope whether synthesized wind shapes for years where historical data …. “    

May also need to inquire/make consideration for that highly accurate solar radiance studies for BPAT should be available in the NREL data set, others BA's may also be contracting for higher accurate studies and making data available.  Consider including in the BPM that more accurate data can be used from other sources, but NREL data will be the base level.

5.  6.5:  

Deb Malin Comment:  "Preserve Reliability mode - ESRs (Batteries) will only be discharged when there is a lack of other resources available.” Question if this assumption will stand the test of time, or if they will be used to serve load as a more cost effective resource in a future market environment.  Suggest that the BPM leaves room and language to allow a change in that modeling assumption if/when the program sees ESR's consistently operating in another fashion. Providing language allow the BPM to stand over time rather then requiring an update to include a different assumption in the modeling of LOLE. 

6.4 Solar Resources

PNM has similar concerns as stated in load modeling.  The difference between our major load pocket and the 5 identified SW weather stations.

APS requests more clarity on the capacity transactions resulting in either a net import or export. This says they would be modeled as generators, is that true for exports? Or would exports be modeled as load? There is more detail in Section 6.9, but it refers to exporting capacity and maintains modeling as a generator. Is there associated FSPRM or FS Capacity Requirements associated with these transactions in and out of the WRAP Region.

Comments provided in Section 04 apply here.