01. Please supply any comments related to the changes in BPM 108: Section Planned Outages 3.1.5.2 (pg. 14)

Bonneville supports these changes. however, we would suggest adding some additional clarifying language to explicitly acknowledge that the replacement for the outage is the participant’s responsibility, and that replacement requirement is limited to the amount needed to meet the participant’s FS Capacity Requirement when accounting for the outage, and not the participant’s original FS demonstration (FS requirement plus surplus). Bonneville proposes the following edits: Participants have the discretion to take planned outages at any time during the Binding Season but are required to take planned outages out of their surplus FS Demonstration capacity or to procure additional supply to replace such capacity on outage. This requirement ensures the participant’s FS Capacity Requirement is available during the Operation Program timeframe. Participants may provide/include information on Qualifying Resources that are planned to be out of service during the specific Binding Season as part of their FS Submittal. This information ensures the QCC for those resources do not utilize capacity that is planned to be out of service to meet a monthly FS Capacity Requirement. Capacity associated with such planned outages shall be deducted from the resource’s QCC that is used in the FS Demonstration for such month(s) as the outage is in effect. Each Participant shall provide a Senior Official Attestation (found in Appendix E – Planned Outages Attestation) by the FS Deadline which states: the sum of expected planned outages at any one time during the Binding Season will be equal to or less than the sum of the outages included in its FS Demonstration plus any surplus identified in the submitted FS Demonstration. If that is not the case, the Participants is responsible for procuring that share of the FS Capacity requirement not met with surplus once all outages are accounted for and the energy needed to meet the Operations Program requirements regardless of planned outage schedules during the Binding Season. A planned outage shall not justify a waiver of, or exception to, a Participant’s Holdback Requirement or Energy Deployment obligations.

02. Please supply any comments related to the changes in BPM 108: Appendix E - Planned Outages Attestation (pg. 21)

Bonneville supports these changes. However, we suggest adding some additional clarifying language, similar to what was noted for section 3.1.5.2 above, to explicitly acknowledge the replacement of capacity lost to planned outages is the participant’s responsibility, and that the scope of this replacement responsibility is limited to the amount needed to return the participant to its FS Capacity Requirement and not the total amount of the participant’s original FS Demonstration (FS Capacity Requirement plus surplus). Below are Bonneville’s suggested language changes/additions to the proposed language in Appendix E section iv: (iv) [Participant] expects the aggregate of any such additional outages to either be equal to or less than [Participant]’s remaining surplus as defined by [Participant]’s Portfolio QCC in excess of [Participant]’s FS Capacity requirement or, to the extent it is not excess, [Participant] will replace the aggregate of any such outages with the necessary capacity or energy to meet the Operations Program requirements, consistent with Section 16.2.8.2 and Part III of the Tariff.

General Comment

Bonneville appreciates the opportunity to provide comments.