01 Please supply any comments related to the Introduction, Definitions, or Background sections.
Idaho Power suggests organizing the BPM and the content in more of outline format with clear “parent” sections and sub-sections following. It can be difficult to follow what overarching topic area a subsection is discussing in the current format.
The interaction between this BPM and BPM 101 - Advanced Assessment is somewhat unclear. For example, are the QCCs of resources determined in the Advanced Assessment process, unless a resource is submitted later? Greater clarity between what is solely addressed in this BPM and what will be addressed in BPM 101 might help, as well as ensuring that the two don’t overlap and cover the same material to the extent possible.
02 Please supply any comments related to the Resource Registration – Resource Eligibility and Timelines section.
No response submitted.
03 Please supply any comments related to the Resource Registration – Late Registration of Resources section.
No response submitted.
04 Please supply any comments related to the Resource Registration – Qualifying Resource Aggregation section.
No response submitted.
05 Please supply any comments related to the Resource Registration – Generator Testing section.
Is this BPM intended to set the deadline for submitting Generator Testing information? We don’t see a specific deadline or process for submitting Capability Testing information.
To the greatest extent possible, generator testing requirements should allow Participants to use results from other required regular testing (i.e., MOD-025). For example, Capability Testing requirements should be able to be met with MOD-025 testing results.
If a resource is co-owned by multiple Participants, test data submitted by one Participant should suffice to meet the requirements of both if the other Participant(s) do not perform that testing individually.
06 Please supply any comments related to the Resource Registration – Operational Testing section.
Operational testing requirements should be flexible to account for a variety of operational and hydrological conditions. There are a number of variables that may need to be taken into account when scheduling operational tests, and at a minimum the testing should allow for use of historical data within the relevant period.
07 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.
No response submitted.
08 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.
No response submitted.
09 Please supply any comments related to the Resource Registration – Provision of Test Reports in the FS Submittal section.
No response submitted.
10 Please supply any comments related to the Resource Registration – Testing for Late Registered Resources section.
No response submitted.
11 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Background section.
The interaction between this BPM and BPM 101 - Advanced Assessment is somewhat unclear. For example, in addressing specific resource types in this section, is the intent to describe only how resources that were not submitted through the Advanced Assessment will be treated? The language seems broader than that could be clarified/targeted to more clearly indicate what is being addressed. A different organization of the subsections (i.e., a hierarchy or outline) may help.
12 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Qualified Resources Included in FS Submittal That Have No QCC Previously Calculated section.
No response submitted.
13 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Thermal Resources section.
Is this section starting on p. 13 intended to address (1) new thermal resources that are included in the advance assessment, or (2) those that are not? If (1), would this also be covered in BPM 101? Regarding the types of thermal resources, is the intent to include geothermal in this list? If (2), is the first portion of this section (up to “Late Registered Thermal Resources,”), relevant for resources not included in the Advanced Assessment for a given season?
Regarding the first bullet on page 16, a participant may not be able to obtain GADS data from a third-party resource owner that is not participating in WRAP, and it is not reasonable to require that information in that case. If a Participant is unable to obtain GADS data for a resource it does not own, but for which it receives all the output under a long-term contract, it should be able to provide information and obtain a QCC for the contract term using either of the methods available to resources that are not required to report GADS data. At a minimum, those options should be available with respect to contracted-for resources for which the contract predated the WRAP program.
14 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Variable Energy Resources section.
Similar questions as to interplay/overlap between this BPM and BPM 101 as described above.
15 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Energy Storage section.
No response submitted.
16 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hybrid Facilities section.
No response submitted.
17 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Demand Response section.
No response submitted.
18 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hydro Resources section.
Are the “Customer Resources” and “Public Utility Regulatory Policies Act (PURPA) Qualifying Facility Resources” sections on p. 29 intended to be part of the Hydro Resources section, as they appear to be? They seem broader than just Hydro and it seems like they should be their own subsections.
In that regard, the “Public Utility Regulatory Policies Act (PURPA) Qualifying Facility Resources” header seems inaccurate based on the text of that section. The text itself indicates that it applies to resources including but not limited to PURPA qualifying facilities so limiting the header to PURPA is misleading.
The option available under that section to non-dispatchable contracted-for resources, or resources that require the purchase to take energy as available from the resource, should be available to such resources regardless of resource type and regardless of whether the contract is with a PURPA qualifying resource or not.
19 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Other Resources section.
There is a typo at the end of “Run of River Hydro” -Other Resources.
20 Please supply any comments related to Appendix A.
No response submitted.
General Comment