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).

NV Energy appreciates the opportunity to comment on BPM 203 – Program Sharing Calculation Inputs. Section 3 Uncertainty Factor introduces a concept where the uncertainty factor, which accounts for forecast variances for load and resources, would be reduced from 10% to 3% when a subregion is deficient. NV Energy does not support the proposed reduction of the uncertainty factor because this could result in a participant being inaccurately calculated as having surplus when the Megawatts are needed to serve their own load. If a participant is inaccurately calculated as having surplus, then they could be subject to non-delivery penalties. The program should identify surplus to help those that are deficient, however, it would not be beneficial to the program to lower the uncertainty in order to calculate additional subregion surplus when it would be harmful to another participant from meeting their load. Therefore, NV Energy does not support a reduction in the uncertainty factor without a protection included for participants which could include a waiver of any non-delivery penalties when the reduction occurs.

General Comment