01: Please supply any comments related to the Introduction, Definitions, or Background sections.
Last sentence of Background references – ‘required to be capable of converting into an Energy Deployment’. This makes it sound like that specific capacity must be converted to energy. We have said that energy does not need to come from a specific set of resources. Suggest changing this to ‘required to have availability for delivery as an Energy Deployment Resource’. This revision would better highlight the distinction between the specific portfolio of resources and resources that are used for the energy delivery.
02: Please supply any comments related to the Sharing Calculation Run (3).
Suggest adding additional words to section v. Total forced outages on transmission lines is not only on those supplying imports but also transmission that removes the deliverability of a participants own physical resources.
v) total forced outages including outages on transmission facilities associated with imports ‘or the specific resources’ utilized by the Participant to meet its Forward Showing Capacity Requirement.
03: Please supply any comments related to the Confirmation of Need for Holdback Capacity (4).
It would be good to mention that the holdback could be released if no one accepts the holdback during the opt-in window (6:00-6:30) of the preschedule day, including reference to section 8.3 regarding Holdbacks not claimed being released.
04: Please supply any comments related to the Voluntary Offers section (5).
Voluntary Offers should not be limited to ‘only’ when a participant has a positive sharing calculation. A participant could have resources surplus to WRAP FS Capacity Requirements, but have a negative sharing calculation due to experiencing an extreme load day. In this scenario, a participant would still have non-program surplus capacity/energy available due to a large portfolio surplus (above and beyond FS Capacity Requirement). A participant in this situation should be free to submit any and all surplus generation (above and beyond program capacity) as Voluntary Offers.
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).
In general, each section needs additional language of ‘How’ capacity is released and ‘How’ participants are notified.
11: Please supply any comments related to the Release of Capacity - Program Early Release of Holdback section (8.1).
Section 8.1 and 8.2 seem like they are actually the same thing; section 8.1 describes what the PO may consider, section 8.2 is the participant requesting that early release. Both of these describe a capability to do this but do not describe the steps or process to request early release (how the participant requests) or how the PO would notify participants that they 1) accept a request or 2) grant a request or 3) notify the requesting participant and notify all other participants that less capacity is now available.
12: Please supply any comments related to the Release of Capacity - Participant Petition for Early Release of Holdback section (8.2).
What happens if a participant’s request for early release is granted and the participant subsequently experiences a major Forced Outage? For example a release is requested 3 days out and the forced outage occurs just ahead of the preschedule calculation. The participant would now have a negative sharing calculation. How would the program address such a scenario?
13: Please supply any comments related to the Release of Capacity - Holdback not claimed on the Preschedule Day section (8.3).
Need expansion of ‘release of capacity’ - failure to confirm causes release. Need to add specific language that all capacity available to the program through Voluntary Offering or Positive Sharing Calculation, above and beyond the issued holdback is released by the program at this time and cannot be recalled. Clarity is also needed that a participant is free to use that capacity in any way, shape, or form they decide without obligation to the program or other program participants.
General Comment
Bonneville appreciates the opportunity to provide comments.