01. Please supply any comment related to the proposed changes in BPM 101 – Advance Assessment
Looks good.
02. Please supply any comment related to the proposed changes in BPM 102 – Forward Showing Reliability Metric
BPM 102 – section 6.1 Thermal Generator modeling
o Edited text reads ‘Thermal Resources or Long Duration Storage Resources’ shouldn’t this be ‘and’ instead of 'or’ and read ‘Thermal Resources and Long Duration Storage Resources’
o At least the first 3 instances of the edit should include both, not one or the other.
03. Please supply any comment related to the proposed changes in BPM 103 - Participant Forward Showing Capacity Requirements
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04. Please supply any comment related to the proposed changes in BPM 104 – Determination of Capacity Critical Hours
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05. Please supply any comment related to the proposed changes in BPM 105 – Qualifying Resources
BPM 105 Qualifying Resources
o Section 3.4.3.1 Thermal Resources and Long Duration Storage – includes edits to change the timeframe around the annual Operational demonstration period, changing it from the current ’12-Month period prior to the FS Submittal due date’ to ’16-Month period prior to the end of the Cure Period’ -- we support the clarifying language, would even suggest it should be modified further so that the period doesn’t run all the way to the due date of the FS submittal. It is impossible for actual operational data that runs all the way through the day the submittal is due to be reviewed by a senior officials, an attestation of that data to be signed and still meet the submittal date/time at 5:00 PPT, when the period doesn't end until midnight on that same day. As a result, participants have to cut the demonstration period short for submittal, review, and attestation purposes only to redo the same work again during the Cure Period, to include the complete set of data. As proposed moving to the 16 months before the end of the Cure Period, results in the same issue in collection of data. It would make more sense for this change to something like the 12-month period ending 30 days prior to the Forward Showing Submittal deadline.
o Sections 3.4.3.2 Storage Hydro Resources – includes the same language ’12-Month period prior to the FS Submittal due date’ as in Section 3.4.3.1 (in multiple places) – why is this definition changing in one section and not being applied uniformly in all places with the same 12-Month period? See previous comment on section 3.4.3.1 for additional thoughts
o Section 3.4.3.3 ESRs, Section 3.4.3.4, Section 3.4.3.5, and Section 3.4.3.6 -- All of these sections are Operational tests, but they do not include a period requirement like in Sections 3.4.3.1 and 3.4.3.2 shouldn’t this same period requirement be included for all Operational Tests?
06. Please supply any comment related to the proposed changes in BPM 106 – Qualifying Contracts
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07. Please supply any comment related to the proposed changes in BPM 107 – Forward Showing Deficiency Charge
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08. Please supply any comment related to the proposed changes in BPM 108 – Forward Showing Submittal Process
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09. Please supply any comment related to the proposed changes in BPM 109 – Forward Showing Transition Period
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10. Please supply any comment related to the proposed changes in BPM 201 – Operations Program Timeline
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11. Please supply any comment related to the proposed changes in BPM 202 – Participant Sharing Calculation Inputs
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12. Please supply any comment related to the proposed changes in BPM 203 – Program Sharing Calculation Inputs
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13. Please supply any comment related to the proposed changes in BPM 204 – Holdback Requirement
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14. Please supply any comment related to the proposed changes in BPM 205 – Energy Deployment
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15. Please supply any comment related to the proposed changes in BPM 206 – Settlement Pricing
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16. Please supply any comment related to the proposed changes in BPM 207 – Settlement Process
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17. Please supply any comment related to the proposed changes in BPM 209 – Energy Delivery Failure Charge
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18. Please supply any comment related to the proposed changes in BPM 210 – Binding and Non-Binding Participation in Operations Program
BPM 210 Binding and Non-Binding Participation in Operations Program
o Section 4 Priority Tier Access When Available Capacity is limited – last sentence of the first paragraph reads ‘Non-Binding Non-Binding’ this looks like a duplication
o Section 4 Priority Tier Access When Available Capacity is limited – that same last sentence (of the first paragraph) looks like it is in contradiction to the 3rd paragraph. Either a Non-Binding participant ‘will not receive Holdback’ or they will receive ‘The second priority’. Don’t believe both can be true at the same time.
19. Please supply any comment related to the proposed changes in BPM 301 – Program Review Committee Workplan Development and Approval
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20. Please supply any comment related to the proposed changes in BPM 302 – Program Review Committee Proposal Development and Consideration
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21. Please supply any comment related to the proposed changes in BPM 303 – Expedited Review Process
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22. Please supply any comment related to the proposed changes in BPM 304 – Amendments to Schedule 1 and WRAP Agreement
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23. Please supply any comment related to the proposed changes in BPM 401 – New Participant Onboarding
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24. Please supply any comment related to the proposed changes in BPM 402 – Protection of Commercially Sensitive and Confidential Information
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General Comment
BPA appreciates all the work that has gone into these updates and the cleanup of BPMs