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

No response submitted.

02: Please supply any comments related to the Derivation of the CCH Analysis Components section (3).

No response submitted.

03: Please supply any comments related to the Derivation of the CCH Analysis Components - Load (Demand) section (3.1).

No response submitted.

04: Please supply any comments related to the Derivation of the CCH Analysis Components - Wind Resource Output section (3.2).

No response submitted.

05: Please supply any comments related to the Derivation of the CCH Analysis Components - Solar Resource Output section (3.3).

No response submitted.

06: Please supply any comments related to the Derivation of the CCH Analysis Components - Run of River Output section (3.4).

No response submitted.

07: Please supply any comments related to the Derivation of the CCH Analysis Components - Interchange section (3.5).

PacifiCorp believes interchange should be excluded from the capacity critical hours completely, in conjunction with the exclusion of resources that are not contracted to WRAP participants, to eliminate the chance of double counting resources that are sold into California. Stated another way, it would be more appropriate for capacity critical hours to be calculated from the WRAP region’s gross load and each WRAP participant’s variable energy resource performance rather than including CAISO’s excess solar or any other non-WRAP load and resources as part of the WRAP calculation.

08: Please supply any comments related to the Determining the CCHs section (4).

No response submitted.

General Comment