Seattle City Light has no comments on this section.
In order to clarify that the language is referring to Qualifying Resources, Powerex suggests the following edit to ii)
“(ii) Participant [has] [does not have] There [are] [are no] certain additional outages at Qualifying Resources that are planned to occur during the [specify season] Binding Season but have not yet begun at the time of submission of the FS Submittal;”
No response submitted.
The language in this attestation seems redundant. The attestation in Appendix A addresses the truth and completeness of the FS Demonstration. A separate attestation with regard to planned outages is not necessary. (If necessary, the language in Appendix A could be expanded, but not to the level of detail currently included here.)
Additionally, this appendix includes language (addressed earlier in NorthWestern’s comments) regarding resources that are currently out of service. Again, whether a resource is out of service at the time of the showing isn’t relevant to the binding season occurring seven months in the future, and it makes the language more complicated than it needs to be. The key is to require all know outages to be submitted (either planned, or unplanned with a return to service date during or after the upcoming binding season).
No response submitted.
No response submitted.
Only attest to ones currently out of service and not the ones that may be out of service in the Binding Season???? It also conflicts with the reference above in the BPM to Appendix E being used to attest that outages won’t be greater than surplus if planned outage information is not available. That could happen even with resources that are currently in service.
Why do replacement resources for those that are on outage have to be located in same place? What is the location attribute referenced (state,region)?
No response submitted.
Planned Outage Attestation -
This attestation forces parties to account for scheduled outages in the FS Submittal.. Discussion has always been that a party could 1) enter outages, thereby reducing QCC values, or 2) attest that outages will be taken out of surpluses and therefore not enter outages..
This seems to be a change in that second concept..
Believe it needs a second part of attestation to identify that - all scheduled outages will be taken from surpluses!