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).
No response submitted.
04: Please supply any comments related to the Contracts Eligible for QCC value - System Sale section (3.2).
3.2.2 – Participant Buyer – Non-Participant Seller. Idaho Power echoes Seattle City Light’s comment that it is unreasonable to require a JCAF or acknowledgement mechanism by both the Participant Buyer and the Non-participant Seller of system sales. WRAP procedures and policies are obligations of Participants.
05: Please supply any comments related to the Joint Contract Accreditation Forms section (4).
Table 1 reflects that a JCAF must be provided the first time a contract is claimed between a Participant Seller and a Non-participant Buyer. This is contradictory to the requirement specified in Section 5, which states that “a JCAF is not required for firm capacity sales to non-WRAP participants.”
Idaho Power believes the requirement to provide a JCAF, signed by the Participant, for sales to non-participant buyers is excessive. Participants are required to list all sales in their Forward Showing and provide an accompanying attestation. This seems sufficient, and the additional requirement for a JCAF is not necessary.
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.
No response submitted.
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
As a general comment, the BPM should be consistent with the tariff unless an explicit change to the tariff has been identified as necessary.
Thank you for the opportunity to provide comments.
Submitted Responses
BPM 106 - Qualifying Contracts
01: Please supply any comments related to the Introduction, Definitions, or Background sections.
02: Please supply any comments related to the Contracts Eligible for QCC value section (3).
03: Please supply any comments related to the Contracts Eligible for QCC value - Resource-Specific Capacity Agreements section (3.1).
04: Please supply any comments related to the Contracts Eligible for QCC value - System Sale section (3.2).
3.2.2 – Participant Buyer – Non-Participant Seller. Idaho Power echoes Seattle City Light’s comment that it is unreasonable to require a JCAF or acknowledgement mechanism by both the Participant Buyer and the Non-participant Seller of system sales. WRAP procedures and policies are obligations of Participants.
05: Please supply any comments related to the Joint Contract Accreditation Forms section (4).
Table 1 reflects that a JCAF must be provided the first time a contract is claimed between a Participant Seller and a Non-participant Buyer. This is contradictory to the requirement specified in Section 5, which states that “a JCAF is not required for firm capacity sales to non-WRAP participants.”
Idaho Power believes the requirement to provide a JCAF, signed by the Participant, for sales to non-participant buyers is excessive. Participants are required to list all sales in their Forward Showing and provide an accompanying attestation. This seems sufficient, and the additional requirement for a JCAF is not necessary.
06: Please supply any comments related to the Calculating Net Contract QCC section (5).
07: Please supply any comments related to the Resource Adequacy Transfers (RA Transfers) section (6).
08: Please supply any comments related to Appendix A.
09: Please supply any comments related to Appendix B.
10: Please supply any comments related to Appendix C.
11: Please supply any comments related to Appendix D.
General Comment
As a general comment, the BPM should be consistent with the tariff unless an explicit change to the tariff has been identified as necessary.
Thank you for the opportunity to provide comments.