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

APS requests that alignment be done between the Definition of Regional Interchange and the discussion around External Capacity Modeling in BPM 102. Are these concepts related or not related, it is unclear to APS currently if they are estimating similar activity or are separate and distinct calculations and uses. If they are separate and distinct some explanation in BPM 102 would be helpful in relation to the Regional Interchange discussion in BPM 104.

In the Background section the list at the end can be better displayed by saying as explained in BPM 105 since each item in the list is explained in BPM 105.

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

No comments at this time.

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

No comments at this time.

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

No comments at this time.

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

In the first line there is an extra word “providing the providing” In the second line it combines solar and wind data, APS thinks the “wind” term was a copy and paste error from the section above.

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

Extra words in first line “providing the providing”.

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

Does the calculation of interchange include EIM transactions or only DA and RT bilateral transactions?  Including EIM transactions could distort capacity positions on both sides of those transactions. In general, APS would like to request a re-look at the section since we are not sure why we use WPP RSG and not what Participants submitted in the Advance Assessment as non-WRAP interchange? It could also be beneficial to incorporate information from non-WPP RSG members of WRAP, or with external resource adequacy programs (CPUC) to get a more complete understanding of Regional Interchange in both terms of economic opportunities and interchange that remains during times of scarcity.

At the end of Section 3.5.1 it says there is a new hourly interchange profile created for the entire 10-year period. APS wonders if this interchange profile would be better represented on monthly basis rather than a seasonal basis?

APS also would like to note the assumption regarding imports to the WRAP Region, these are considered imports no matter the market prices at the time, with changes in export priority in surrounding markets this may be necessary to re-visit.

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

No comments at this time.

General Comment