City Light has no comments on this section of the BP.

• Under 'Additional Thermal QCC Calculations Considerations (pg. 16) - 1st three bullt points - These are repeats from above
• Under 'Qualified Resources That Are Not Required to Report GADS Data' - Option 1 - Historial Output - 1st sentence - Why do we care about LLH?   Our monthly data would underestimate QCC b/c we load factor during LLH and choose to do scheduled maint during low load periods… (e.g. monthly average brought down because we choose to save water in LLH or do maintenance in LLH. ‘during CCH’  -- important note, only look at CCHs not a 744 average of both HLH and LLH

• Table 4 – page 15 – FOH and EFDH definitions are missing the sub script of CCH used in formulas.

It would be helpful to address the following items in the BPM,

a) Why was EFOF selected instead of the more standard EFORd for UCAP accreditation? It would be helpful to have the rationale behind this choice along with details on the choice of the denominator utilizing CCH rather than the GADS defined denominator for EFOF. Were the Forced Outage Rates (FOR) for each unit utilized in the advanced assessment for establishing the PRM? It would be helpful to make sure the differences are noted, if any exist, between the advanced assessment to establish PRM and for capacity accreditation.

b) The paragraph references both EFOF and “equivalent outage rate”. To avoid confusion, please clarify if the rate is calculated from the factor? Noting the distinction of “factor” and “rate” in the context of GADS. <Reference>

c) Please include the rationale on why 70% of the class average is being proposed to be utilized.

d) APS requests that the PO provide the CCH and associated application of the formula for each of its thermal units.

Is this section starting on p. 13 intended to address (1) new thermal resources that are included in the advance assessment, or (2) those that are not?  If (1), would this also be covered in BPM 101?  Regarding the types of thermal resources, is the intent to include geothermal in this list?  If (2), is the first portion of this section (up to “Late Registered Thermal Resources,”), relevant for resources not included in the Advanced Assessment for a given season?

Regarding the first bullet on page 16, a participant may not be able to obtain GADS data from a third-party resource owner that is not participating in WRAP, and it is not reasonable to require that information in that case.  If a Participant is unable to obtain GADS data for a resource it does not own, but for which it receives all the output under a long-term contract, it should be able to provide information and obtain a QCC for the contract term using either of the methods available to resources that are not required to report GADS data.  At a minimum, those options should be available with respect to contracted-for resources for which the contract predated the WRAP program.

 No comment at this time.