City Light has no comments on this section.  

Can more information be provided on the data source used to estimate the cost of the natural gas-fired generation facility? Previously, we’ve seen estimates from public sources that were significantly lower than APS’ cost to build a new facility. APS recommends that WRAP keep the CONE value and how it is derived in mind as the resource mix of Participants evolves, we can see scenarios where blending bids from across the footprint or having this reflect actual projects that have been installed within WECC could be more accurate reflections that incent behaviors to comply with FS Capacity Requirements.

The language in 3.3.2 should say “greater than or equal to” for the odd situation where the deficit is exactly 1, 2 or 3%. The same comment applies to the Winter % Deficit calculation.

APS requests information on where the CONE is posted to the website, also a timeline/table of when a CONE that is approved is effective for, in terms of Forward Showing seasons. Along with when the CONE will be updated for subsequent Forward Showing Seasons into the future. APS also would appreciate more information related to how Participants can play a role in the CONE review performed by the Program Administrator annually, as Participants can have valuable input.   

1.  3.3.1:  Changes to the Cone need more details than what is currently captured. The Cone factor that will be used in the assessment of a charge due to a deficiency in Forward Showing needs to be posted prior to the submission deadline.  That is the cone charge that will be used for that filing. The next seasons change could be different, but also posted and associated with that Forward Showing filing.

2.  3.3.2:  The final paragraph indicates Non-zero Summer % Deficit or Winter % Deficit --- and the immediately following ……. Shall be 200%.  Doesn’t the described factors for both summer and winter establish the factor any time someone has a deficit?  Or is this saying that if the program is good and then someone experiences a deficit that we imediately go to the maximum factor for a season? That seems like an excessive penalty, when we already have a structure in place to determine the factor.