In Section 6.1 it refers readers to BPM 101 Advance Assessment for details related to the Capability Test, however there is not details in BPM 101 on the Capability Test. APS commented on BPM 105 where the details of the Capability Test are located that they should be included in BPM 101, but they were not included. APS comment on BPM 105 question 9 in the template reads, “Please supply any comments related to the Resource Registration – Provision of Test Reports in the FS Submittal section.

APS believes the Capability Test should reference submission at the Advance Assessment in this paragraph, the way it reads makes us believe there is a capability test submitted at the FS Submittal which is false.”

“For thermal resources that do not submit such data, an average forced outage rate will be applied based on size, technology type, Fuel Type and resource age”

Please verify that this assumption is consistent with BPM 105 and that class average outages are in fact utilized in lieu of missing GADS data.

Section 6.1 states, “The Capability Test data will be provided by each Participant in its annual data submittal, as described in BPM 101 Advance Assessment.” Idaho Power assumes this sentence intends to refer to NERC GADs data and not Capability Test data. Specifically, the sentence should state, “NERC GADs data will be provided by each Participant in its annual data submittal, as described in BPM 101 Advance Assessment.” The requirement to submit Capability Test data is described in BPM 105 Qualifying Resources, Section 3.4.2., wherein the requirement is that Participants will submit this data every five years. Please review and clarify as needed. Thank you.

SRP recognizes the importance of accurately modeling forced outages for thermal resources in the LOLE Study. SRP requests clarification on whether forced outages for thermal resources are modeled stochastically in the LOLE study based on the time to failure and time to repair data provided from Generating Availability Data Systems (GADS). For greater clarity, SRP recommends explicitly stating in this section of the BPM whether such data informs the stochastic modeling of forced outages.