COMMENT FOR BPM 108 - Forward Showing Submittal Process

Submitted Jan. 5, 2024, 9:42 a.m.



01: Please supply any comments related to the Introduction, Definitions, or Background sections.

No response submitted.

02: Please supply any comments related to the Forward Showing Submittal and Cure Period section (2).

No response submitted.

03: Please supply any comments related to the Forward Showing Submittal Materials section (3).

No response submitted.

04: Please supply any comments related to the Forward Showing Submittal Materials - FS Demonstration section (3.1).

No response submitted.

05: Please supply any comments related to the Forward Showing Submittal Materials - Loads section (3.1.1).

No response submitted.

06: Please supply any comments related to the Forward Showing Submittal Materials section - Qualifying Resources section (3.1.2).

No response submitted.

07: Please supply any comments related to the Forward Showing Submittal Materials - Contracts section (3.1.3).

No response submitted.

08: Please supply any comments related to the Forward Showing Submittal Materials - Transmission section (3.1.4).

No response submitted.

09: Please supply any comments related to the Forward Showing Submittal Materials - Planned Outages section (3.1.5).

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.

10: Please supply any comments related to the Forward Showing Supporting Materials section (3.2).

No response submitted.

11: Please supply any comments related to the Forward Showing Supporting Materials - Testing section (3.2.1).

No response submitted.

12: Please supply any comments related to the Forward Showing Supporting Materials - Thermal Resources that are not Required to Report GADS Data section (3.2.2).

No response submitted.

13: Please supply any comments related to the Forward Showing Supporting Materials - Hydro Resources section (3.2.3).

No response submitted.

14: Please supply any comments related to the Forward Showing Supporting Materials - Late Registered Resources section (3.2.4).

No response submitted.

15: Please supply any comments related to the Forward Showing Supporting Materials - Transition Exceptions section (3.2.5).

No response submitted.

16: Please supply any comments related to the Cure Period section (4).

No response submitted.

17: Please supply any comments related to Appendix A.

No response submitted.

18: Please supply any comments related to Appendix B.

No response submitted.

19: Please supply any comments related to Appendix C and D.

No response submitted.

20: Please supply any comments related to Appendix E.

No response submitted.

21: Please supply any comments related to Appendix F.

No response submitted.

22: Please supply any comments related to Appendix G.

No response submitted.

General Comment

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