PAC would appreciate additional clarity in this section in regard to how planned outages affect resource QCCs in the Forward Showing.

PAC is lead to understand by the language of this section any planned outage for a resource lasting five or more days reduces the resource's QCC to zero for the given month in the Forward Showing. 

The following passage implies potential different treatment for resources offline at the time of Forward Showing submittal whose outages will extend into the binding season, versus resources available at the time of FS submittal but with planned outages overlapping with the binding season. The passage does not clearly address the latter these implied categories, into which most planned outages would likely to fall:

"Any Qualifying Resource that is out of service at the time of the FS Deadline and is planned to remain out of service for five or more days of a month in the Binding Season cannot have such Qualifying Resource’s QCC counted toward meeting the Participant’s FS Capacity Requirement for that month"

PAC would suggest a resource QCC reduction proportional to expected resource availability during the binding month, instead of the all-or-nothing approach of this BPM. PAC would prefer something like a "planned outage factor" to apply to the monthly QCC. This would be calculated and applied as follows: (# of days resource is available / # of total days in month) * QCC. 

PAC further notes planned outages are often intended to be contained to shoulder months, but personnel, parts or schedule availability may force planned outages to be scheduled into the the early weeks of June or November, when RA risk is generally low. 
 

NV Energy appreciates the ability to be able to comment on the Western Power Pools Business Practice Manual 108 prior to final approval.  NV Energy recommends that Section 3.1.5 provide more clarity about planned outages during a Forward Showing Season and provides a comment on the outage length within a Forward Showing season. It is important for participants to understand when capacity would not qualify in meeting the Forward Showing requirement, therefore, the planned outage section should be more clear.   It is unclear if all planned outages are required to be excluded as capacity to be applied towards the Forward Showing requirement. For instance, if the resource was planned to be on outage for 1 day within a month during the Winter or Summer season or if only outages that extend beyond 5 days are excluded. NV Energy does not support the proposal that completely results in an exclusion of capacity when a planned outage extends a little into a Forward Showing month.  Planned outages may extend into a month for a few days, but the resource would be available during the remaining part of that month and should be able to qualify towards the Forward Showing requirement.  The Western Power Pool should consider a percentage approach of the qualifying capacity amount rather than excluding all capacity from that resource towards the Forward Showing requirement.

The second paragraph of this section begins, “A Participant’s FS Demonstration shall include information on all Qualifying Resources that are out of service at the time of the FS Deadline that plan to return to service after the first five days of the Binding Season.”  Whether the resource is offline at the time of the FS Deadline doesn’t seem relevant.  The requirement should be that the FS Demonstration include information on any outages that are scheduled for any part of the binding season (regardless of whether the resource is offline at the time of the FS Deadline), and that any resource scheduled out for more than the first five days of a binding season cannot be counted for the first month of that season (assuming that is the intention of this section).

The third paragraph has a reference to outages “not yet begun at the time of the FS Deadline.”  Again, the FS Deadline does not seem relevant here.  Regardless of the start date of the planned outage, the requirement should be the same (i.e. if the outage extends beyond the first five days of a Binding season, the Capacity is deducted from the Participants resources).

Also in this section, the language does not specifically address planned or known transmission outages that affect the delivery of certain resources.  Please consider adding language to address this situation.

Idaho Power suggests revisions to this section. The BPM recites language directly from the Tariff, which is difficult to follow, and does not provide additional specification or clarification. Idaho Power recommends that WPP include language in the BPM that specifies how planned outages that are expected to start after the FS deadline and continue into the binding season will be accounted for in the Forward Showing, and if not included in the Forward Showing, how they will be accounted for in the Operations Program. This detail is needed to ensure consistent treatment among participants and that the Operations Program results are based on the most complete information.

Seattle City Light has no comments on this section.

In general, APS is wondering why we are concerned about the status of a resource at FS Deadline? The FS is for months 7 months away, why don't we focus on the status of resources in the Binding Season? Much of the section discusses a scenario where a resource is unavailable at the time of FS, rather than discussion how to account for and submit planned outages that are known at the FS Deadline.

Also, APS has previously communicated planned outage representation in the FS should be reflective of the highest day of planned outages in the month. APS supports the following language be added to this section to capture this aspect. “For the highest day of cumulative planned outages in a month during a binding season, any planned outages taken on resources will result in the QCC of those resources being reduced to zero for the month. Highest day of cumulative planned outages in a month shall be calculated as the highest sum of QCC for resources on planned outage for each day of the month.” APS disagrees with the language in the BPM that states, “Participants shall provide information on all Qualifying Resources that are planned to be out of service during the Binding Season in their FS Demonstrations as part of their FS Submittal…”, as this should only be required if the outage is planned during the highest day of cumulative planned outages. APS strongly believes you can't count all outages on all Qualifying Resources that don't overlap in the month as unavailable for meeting the FS Requirements.

What is the QCC for resources that are out 1 to 4 days of a month? Does this have to be the first four days of the month?

Any guidance on how to handle outages that are only a few days of a month or a part of the month will be helpful.

There is language for outages at the time of FS filing, and for outages after FS filing. There is language for the number of days out in the first five days part of the FS season. There is attestation possibilities under two different scenarios. Could you please provide a Table to help clarify what the requirements are? It is difficult to decipher the requirements from the language in this section.

This section could also clarify which of the two different classes of outages specified are to be in included in the FS workbook.