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

No response submitted.

02: Please supply any comments related to the Sharing Calculation Run (3).

No response submitted.

03: Please supply any comments related to the Confirmation of Need for Holdback Capacity (4).

No response submitted.

04: Please supply any comments related to the Voluntary Offers section (5).

No response submitted.

05: Please supply any comments related to the Optimization Allocation section (6).

No response submitted.

06: Please supply any comments related to the Optimization Allocation - Subregion with Central Hub section (6.1).

No response submitted.

07: Please supply any comments related to the Optimization Allocation - Subregion without Central Hub section (6.2).

No response submitted.

08: Please supply any comments related to the Optimization Allocation - Ensuring Whole MW Holdback Capacity section (6.3).

No response submitted.

09: Please supply any comments related to the Bilateral Transfer of Holdback section (7).

No response submitted.

10: Please supply any comments related to the Release of Capacity section (8).

No response submitted.

11: Please supply any comments related to the Release of Capacity - Program Early Release of Holdback section (8.1).

No response submitted.

12: Please supply any comments related to the Release of Capacity - Participant Petition for Early Release of Holdback section (8.2).

Idaho Power has general concerns with this section and believes it warrants more discussion. The BPM doesn’t reference any metrics or guidelines for meeting criteria to justify early release of holdback. Idaho Power also supports continued discussion on the extenuating circumstances listed in the BPM that may justify early release of holdback.  

13: Please supply any comments related to the Release of Capacity - Holdback not claimed on the Preschedule Day section (8.3).

No response submitted.

General Comment