BPA believes that the DR QCC workbook should incorporate the simultaneous calculation of daily and hourly fatigue. Many DR products will experience a loss of capacity over multiple hours of use and multiple days of use. Calculating both factors will more accurately reflect the real-world performance of DR products and lead to more accurate QCC values. This is an area of potential improvement going forward, and not reflective of a critical concern that warrants revision to the Task Force’s proposal.

The implementation approach is reasonable and appropriately phased with a non-binding Forward Showing prior to binding adoption.