01: Please supply any comments related to the Introduction, Definitions, or Background sections.
There is a small error in the Summer and Winter % Deficit Definitions where the word “great” should be “greater”. Also, for these definitions is the denominator actually P50 Peak Load Forecast? APS believes that this may be best calculated by using the FS Capacity Requirements of the WRAP Participants, if P50 Peak Load Forecast is correct could the rationale of it’s use as compared to the FS Capacity Requirement would be beneficial in the body of the BPM.
02: Please supply any comments related to the Calculating the Deficiency Charge section (3).
No comments at this time.
03: Please supply any comments related to the Calculating the Deficiency Charge - Calculating the Deficiency section (3.1).
No comments at this time.
04: Please supply any comments related to the Calculating the Deficiency Charge - Calculating the Deficiency Charge section (3.2).
There is a paragraph of information related to Formula 2 that appears after Formula 3. If possible, it may be best to put this information preceding Formula 2 as is the case with the descriptions of Formula 1, and 3-4.
05: Please supply any comments related to the Calculating the Deficiency Charge - Determining Certain Components of the Deficiency Charge Calculation section (3.3).
Can more information be provided on the data source used to estimate the cost of the natural gas-fired generation facility? Previously, we’ve seen estimates from public sources that were significantly lower than APS’ cost to build a new facility. APS recommends that WRAP keep the CONE value and how it is derived in mind as the resource mix of Participants evolves, we can see scenarios where blending bids from across the footprint or having this reflect actual projects that have been installed within WECC could be more accurate reflections that incent behaviors to comply with FS Capacity Requirements.
The language in 3.3.2 should say “greater than or equal to” for the odd situation where the deficit is exactly 1, 2 or 3%. The same comment applies to the Winter % Deficit calculation.
APS requests information on where the CONE is posted to the website, also a timeline/table of when a CONE that is approved is effective for, in terms of Forward Showing seasons. Along with when the CONE will be updated for subsequent Forward Showing Seasons into the future. APS also would appreciate more information related to how Participants can play a role in the CONE review performed by the Program Administrator annually, as Participants can have valuable input.
06: Please supply any comments related to the Timing of Deficiency Charge Revenue Collection section (4).
APS would appreciate additional information surrounding the timeline related to “directly following the end of the Cure Period for each season”. Is there a more standard invoicing timeline that can apply here after each Cure Period?
07: Please supply any comments to the Allocation of Revenues from Deficiency Charges section (5).
No comments at this time.
08: Please supply any comments related to the Board Appeal Process section (6).
Suggest moving this section above the collection and allocation sections, the reason is that the allocation section waits for the appeal process to conclude. Alternatively, it may make sense to break this section out between appeal process, appeal settlement impacts. With the appeal process moving up, and the appeal settlement impacts remaining in this area.
General Comment