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

No response submitted.

02: Please supply any comments related to the Uncertainty Factor section (3).

PacifiCorp understands the uncertainty requirement is intended to fit within the PRM, along with the Contingency Reserve requirement, which is always a minimum of 3% of generation and 3% of load. In a month where 10% uncertainty, 3% of generation, and 3% of load do not fit into within the PRM (for example, July Mid-C PRM of 14.5%), what are the effects? Please elaborate on any operational consequences of this scenario, which is expected to regularly occur.

The 10% uncertainty requirement, while simple, does not reflect the true nature of operational requirements. 10% could be excessive overnight, while insufficient during the net demand peak hours. WEIM participants are currently accustomed to planning around an hourly requirement which is tailored to each entity and provided on a day ahead basis. PacifiCorp understands the Uncertainty WG will revisit the requirement after two or more seasons of operations data has been captured, but is of the opinion the current requirement does not accurately reflect the true needs of the region and will expect it to change. This BPM does not substantiate the 10% requirement with any data. Methods currently exist and are employed to calculate reasonable uncertainty requirements. WPP may consider consultation with such entities when the time comes to revise the 10% requirement.

PacifiCorp would like Participants to be made aware of when the Program Operator is reducing the uncertainty requirement, and the extent to which it has been reduced.

PacifiCorp also needs to better understand what will happen if a reduction of uncertainty to 3% does not cure an aggregate subregion deficiency. Please elaborate further in this BPM.

Additionally, this BPM does not discuss any effects on a Participant’s ability to call upon transmission to fulfill a holdback obligation that is sourcing holdback from a subregion in which the uncertainty requirement has been reduced. Does any uncertainty reduction, even to the minimum of 3%, “block” a Participant’s ability to utilize this transmission?

General Comment