COMMENT FOR BPM 106 - Qualifying Contracts

Submitted April 11, 2024, 11:49 a.m.



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

No response submitted.

02: Please supply any comments related to the Contracts Eligible for QCC value section (3).

No response submitted.

03: Please supply any comments related to the Contracts Eligible for QCC value - Resource-Specific Capacity Agreements section (3.1).

Powerex suggests that section 3.1.iv be revised and remove “long-term firm”, which is unnecessary, from the language associated with conditional firm service.

04: Please supply any comments related to the Contracts Eligible for QCC value - System Sale section (3.2).

Powerex suggests that section 3.2.2 be revised and remove “long-term firm”, which is unnecessary, from the language associated with conditional firm service.

We also recommend that language identifying the buyer and seller of a system sale be modified to be more concise. In section 3.2.1, the first sentence should read “A System Sale for which the buyer is a Participant and the seller is a Participant...”. The same modification could be applied to section 3.2.2 and 3.2.3

05: Please supply any comments related to the Joint Contract Accreditation Forms section (4).

Powerex notes there is an incorrect reference to Section 43.2, which should instead be Section 3.2

06: Please supply any comments related to the Calculating Net Contract QCC section (5).

No response submitted.

07: Please supply any comments related to the Resource Adequacy Transfers (RA Transfers) section (6).

No response submitted.

08: Please supply any comments related to Appendix A.

In the final sentence, Powerex believes this should read “network integration transmission service rights”.

09: Please supply any comments related to Appendix B.

No response submitted.

10: Please supply any comments related to Appendix C.

No response submitted.

11: Please supply any comments related to Appendix D.

No response submitted.

General Comment

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