No response submitted.
No response submitted.
Section 3.1.4.1
Should the 5:00 PPT time be 17:00 PPT (i.e. close of business)?
Section 3.1.4.1.2
Please consider clarifying the language for item 2 as follows “The Participant provides evidence that its transmission service provider has released additional NERC Priority 7 or 6 Firm PTP or network integration service in all of the CCHs in the most recent Summer or Winter Binding Season, as appropriate, on the applicable path following the FS Deadline;”
No response submitted.
No response submitted.
APS thinks this could be better clarified to reflect the expectations of Participants. Particularly, the sentence, “The FS Demonstration shall include information on the Participant’s transmission service reservations that it reasonably plans to utilize in the upcoming Binding Season.” - Is it all reservations or only those used to meet the 75% that a Participant should include in the Transmission section of the FS? Also, "shall include" followed by a Participants judgment of "reasonably plans to utilize" is confusing.
In section 3.1.4.1.1 Enduring Constraints there is discussion around constraints around segments. APS is interested in what the definition of segment is, and why is it segment, or is it a single POR/POD combination? A POR/POD combination can be made up of multiple segments, and segment has a specific meaning on OASIS for transmission reservations, so want to make sure if we are intending align with the use of segment on OASIS, or is segment defined by WRAP independently. For section 3.1.4.1.3 Transmission Outages and Derates APS is wondering if we need to report this exception or any exception possibility in the instance where the 75% FS transmission requirement is met? Our belief is no exception information is needed if a Participant meets the 75% FS threshold, is that accurate and if so, can we explicitly mention that in the BPM?
In section 3.1.4.1.4 Counterflow of a Qualifying Resource the last paragraph states, “Counterflows that involve three or more BAAs as sources and sinks will not qualify for the Counterflow of a Qualifying Resource exception.”. APS believes that it is not possible to have more than 2 BAAs as sources/sinks, so this situation of having 3 or more as sources/sinks is not possible and propose deleting “…as sources and sinks…”.
It might be helpful to clarify that conditional firm transmission is acceptable in addition to listing the NERC priority codes.
3.1.4.1.2: Should be listed as "NERC Priority 6 or NERC Priority 7 firm point-to-point transmission service or network integration transmission service (NITS)" for clarity
For Bullet #3 in this section, is NITS an option for this criteria?
3.1.4.1. Transmission Exceptions
- Future Firm ATC [available transmission capability] Expected";
Second and third bullets were run together on the same line.
"All Participants requesting a Monthly Transmission Exception are responsible for submitting the completed Transmission Exception request form found on the WPP "
Include either link to the form or the actual form as part of the Appendix C.
"by 05:00 PPT on the 60th day after the FS Deadline."
Again 05:00 is 5am
"the Participant has acquired a different resource with the necessary firm transmission and no longer requires the Monthly Transmission Exception."
Does the replacement resource notification require a QCC? Or to meet standard contract requirements for establishing QCC through a JCAF - seems to be missing?
"If a Monthly Transmission exception is denied (either because it is invalid or because circumstances changed and transmission has become available during the review period),"
What if deemed 'invalid' and therfore denied after cure period?
In the described example (above) Future period would be February 28th, what if WPP determines the monthly check-in is denied in March - does a participant have 30 days to rectify before being assessed a failure charge?
Participant should ALWAYS receive time to solve a problem before receiving a charge, after an initial acceptance/approval of an exemption, and filing a monthly check-in, and receiving a Denied notification.
3.1.4.1.1. Enduring Constraints
"any single segment of a source-to-sink path for a resource (exceptions will not be granted for two segments of a source-to-sink path)"
Is this new? Do not recall the single segment restriction. There will likely be situations where two segments have constraints and no available firm transmission. Consider allowing multiple segment exceptions.
"for all CCHs in the most recent same season from the most recently available CCH data set;"
'Most Recent' shouldn’t this be the CCH used for the analysis/determination/ Forward Showing submittal…. If a new set of CCH's are released 30 days before a FS deadline, Participants cannot be expected to adopt new CCH's and incorporate them in all submittal functions.. Exemptions could take months of leg work to pull together, changing the CCH's at short notice should facilitate the use of previous. Sr official Attestations will require that FS submittals are complete well ahead of due date in order to get approvals.