01. Please supply any comments related to the definition of Generation Facility and Transmission Facility (Section 1.4)

Bonneville opposes 2024-CFR-009 as a Non-Task Force Proposal, and requests that this proposal go through the PRC task force. Bonneville believes there could be un-intended consequences associated with including definitions pertaining to the FS program into the Operations program waiver process. These un-intended consequences are likely to limit flexibility in the operational window and increase the cost of participation. Un-intended consequences include, but are not limited to: • Changing how energy delivery can be met operationally • Definition changes could create a path for waiver of delivery failure because a firm transmission right was curtailed while non-firm was still available. • Failure to deliver charges already incentivize entities to use firm transmission whenever possible and to ensure delivery is made even when using non-firm transmission. A stronger definition could cause entities to hold an excess amount of firm transmission, which in turn limits the amount of transmission available for others, driving up the cost of program compliance.

General Comment

Bonneville appreciates the opportunity to provide comment. As stated above, Bonneville is concerned that these edits will have unintended consequences with other parts of the Operations program.  Creating definitions under BPM 209, and specifically tying them to the Energy Delivery Failure Charge and possible waivers, could create ripple effects into other OPS program areas.  Bonneville has concerns regarding these proposed changes because the program has been built around an expectation that once a participant receives a holdback notification and ultimately an energy deployment notification, there is a large degree of discretion given as to how those deliveries are completed.  While not the intention of the program, this could mean that delivers are made from non-WRAP eligible resource or across non-firm transmission, but in the end the energy delivery is made, and the reliability of the WRAP footprints are maintained.  Tightening these definitions under the waiver process seems to undermine this deference regarding delivery and needs further review. Bonneville is unsure if tightening these definitions increases the probability that the energy deliveries are made when called upon or could unintentionally create a loophole for entities utilizing a waiver to get out of an energy delivery, when the sharing calculation says such a delivery is possible.