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.