In this section in the 2nd sentence it would be best to also indicate that the WRAPA signing period is no sooner that August 15th and no later than September 15th. APS believes that the New Participant Limited Data Request also needs to include load values, and not just values to inform approximated QCC values so that the Program Operator can provide a load requirement to the New Participant. Is it worth having a 2nd path to participation than the one in Table 1, the 2nd path would have the Participant starting at the Advance Assessment so that no class average QCC’s are needed? In Table 2, our math would put the Summer FS Deadline on October 31st, 2026 and not 2027. The showing would be for Summer 2027 we think but the year it is submitted is 2026.
No response submitted.
Overall comment on Table 1 - dates indicated in table for using participant submitted Advanced Assessment data for QCC’s are wrong. Section 4.1.1 notes it correctly as the first 2 seasons use class average numbers.
Comment on Table 1 - First Summer FS Deadline: Does this FS come with binding Cone Charges/Capacity Chargers? We want to encourage entities to join, this feels like it forces a new participant to know beyond a reasonable doubt that they will pass Forward Showing before they Execute a WRAPA - no season to verify that they have done everything correctly!
Comment on Table 1 - First Binding Operations Season: Concerned over this first Operation period being a binding season - and the potential for bad data (not production quality). By this season being binding a new participant doesn’t have a period to see OPS in process and understand how their data fits and work out bugs. Maybe something even as simple as June is a voluntary month and July-Sept is binding would help address this concern.
Comment on Table 1 - Summer FS Deadline: “this showing will be the first using QCC values for resources Participant turned in at its first Advance Assessment” – Saying that the Summer submittal in year 1 uses QCC values from the participants first Advanced Assessment does not give the 1 year notice on those values to the participant, the participant’s first Advanced Assessment submittal only happened in 8 months before. These values would still be class average, or be used with less than 1 years notice! The QCC’s used during the first October would have been published 1 year in advance of FS submittal deadline that would be the October immediately after they became a participant, and before they submitted there first Advanced Assessment in March. Section 4.1.1 reflects this timing correctly.
Comment on Table 2 - First Summer FS Deadline: QCC’s and PRMs need to be published a minimum of one year in advance (October 23). Use class average.
Comment on Table 2 - Deadline for First Advanced Assessment data submittal: Table 2 should reflect all lines of table 1 based on a specific year.
Comment on Table 2 - Summer FS Deadline: This jumped forward to 2027? October 31 2025 would still be using calculated QCC’s and PRMs from the 2023 Advanced Assessment (before they became a participant). Need to use class average.