COMMENT FOR BPM 202 - Participant Sharing Calculation Inputs

Submitted July 26, 2024, 9:36 a.m.





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

For the Forced Outage definition: does the reference to “capacity” pertain to capacity or QCC? Bonneville recommends that the definition be modified to include the following:

Storage Hydro QCC, and

loss of generating capability due to emergency transmission line outage

02: Please supply any comments related to the Components of the Sharing Calculation equation section (3).

No response submitted.

03: Please supply any comments related to the Inputs from the Forward Showing Submittal section (4).

No response submitted.

04: Please supply any comments related to the Inputs from the Operations Program section (5).

No response submitted.

05: Please supply any comments related to the Inputs from the Operations Program - Load Forecast section (5.1).

Bonneville requests further clarification on the meaning of “regular” and “mitigate” in the following sentence: The Program Administrator/Program Operator will evaluate on a regular basis forecast performance and deviations to identify and mitigate inaccurate data.

06: Please supply any comments related to the Inputs from the Operations Program - Forced Outage Forecast section (5.2).

Section 5.2 does not tie back to adjusted QCC’s in any way except the ‘additionally’ note. Also, storage hydro adjusted QCC’s should be described here.

This entire section should focus on a theme of adjusted QCC values.

07: Please supply any comments related to the Inputs from the Operations Program - Forecasted ROR section (5.3).

No response submitted.

08: Please supply any comments related to the Inputs from the Operations Program - Forecasted wind output section (5.4).

Bonneville requests further clarification on the meaning of “regular” and “mitigate” in the following sentence: The Program Administrator/Program Operator will evaluate on a regular basis forecast performance and deviations to identify and mitigate inaccurate data.

09: Please supply any comments related to the Inputs from the Operations Program - Forecasted solar output section (5.5).

Bonneville requests further clarification on the meaning of “regular” and “mitigate” in the following sentence: The Program Administrator/Program Operator will evaluate on a regular basis forecast performance and deviations to identify and mitigate inaccurate data.

10: Please supply any comments related to the Inputs from the Operations Program - Contingency Reserves Obligation section (5.6).

No response submitted.

11: Please supply any comments related to the Inputs from the Operations Program - Uncertainty Factor section (5.7).

No response submitted.

12: Please supply any comments related to the Input Data Files section (6).

No response submitted.

13: Please supply any comments related to the Input Data Files - Multi-Day file section (6.1).

No response submitted.

14: Please supply any comments related to the Input Data Files - Operating Day file section (6.2).

Previous discussions had indicated extending this to 72 hours’ worth of data to allow for data coverage over weekends and holidays. If the system can already accommodate submitting 72 hours’ worth of data, then this should be written as a minimum of 24 hours’ worth of data, and up to 72 hours of data is requested.

15: Please supply any comments related to the Input Data Files - Point Limit file section (6.3).

No response submitted.

16: Please supply any comments related to the Input Data Files - Point to Point Limit File section (6.4).

No response submitted.

17: Please supply any comments related to the Input Data Files - Voluntary Holdback File section (6.5).

No response submitted.

18: Please supply any comments related to the Input Data Files - Actuals file section (6.6).

Please clarify if AC files must be submitted 7 days after the relevant operating day or 168 hours after the relevant operating hour.

19: Please supply any comments related to the Calculation of Sharing Results section (7).

No response submitted.

20: Please supply any comments related to the Planned Outages section (8).

Bonneville suggests the following additions be made to this section:

The aggregate of any additional outages that are planned to occur during the Binding Season but have not yet begun at FS Submittal deadline must be within the Participant’s remaining surplus or replaced with other supply or incorporated in the calculation of QCC that is submitted in Forward Showing.

21: Please supply any comments related to Appendix A - Data Attestation

Where and when would this attestation be made/used? The operations program is a daily/hourly data submittal. When, how, and at what point would this attestation be expected?

General Comment

Bonneville appreciates the opportunity to provide comments

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