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

No response submitted.

02 Please supply any comments related to the Resource Registration – Resource Eligibility and Timelines section.

• What happens if you contract after this deadline?   Should provide ability to add resources X (3?) months prior to the season it will be used?
• In the table, item, 'Ownership or Contracted Percentage for Participant' - Resource registration is part of advance assessment - this isn't needed until FS is it? Need clarification please.
• In the table, item, 'Summer Max Capacity or Nameplate (MW)' - Should this be an 'or' vs. 'and'? - same with the 'Winter Max Capacity or Nameplate (MW) item
• Table 2 - Thermal Resources, last sentence, '...as post in an appropriate location on WPP website.' - is very vague. Is there a link available?
• Table 2 - Wind, ROR Hydro, Solar Resources - Why are they requiring annual data when we only really care about capacity critical hours during the summer and winter seasons.  E.g. Using annual generation data may lower the capacity factor b/c we load factor to save water for HLH. 
• Table 3 - 'Ownserhip or contracted % for participant' - Resource Registration is part of Advance Assessment – this isn’t needed until Forward Showing is it?  Need clarification

03 Please supply any comments related to the Resource Registration – Late Registration of Resources section.

No response submitted.

04 Please supply any comments related to the Resource Registration – Qualifying Resource Aggregation section.

• 2nd paragraph - '...in close proximity...' - This feel pretty arbitrary.  For one the PO could decide 50 miles is close enough for another it needs to be within 25?  Guidelines would be good.

05 Please supply any comments related to the Resource Registration – Generator Testing section.

• Capability Test Requirements for Thermal Units - Is this a standard from someplace else?  Or was this created by WRAP?  If it is someone else’s standard (such as NERC) why wouldn’t we point to that standard, if they go through the public process to change the standard it would automatically be reflected in the WRAP standard,  and not require us to go through a PBM update?

06 Please supply any comments related to the Resource Registration – Operational Testing section.

• Storage Hydro Resources - 2,3, & 4th sentences - Question if the previous season is the correct.  For Thermal units we say once every 5 years, for storage we are only giving a single point in the previous season – this should probably be on equal footing – previous 5 years (applicable to the correct season).  If last year was an extremely dry year, or had a flood of other resources available on the market someone may have chosen to not operate at peak levels..  which in theory as written could cause a limitation in the following years WRAP QCC  under this test…  This should be over multiple years to not create that issue.
• ESRs - ESR, ROR, Wind/Solar do got give a data range for operational test..  Thermal says 5 years, Storage says same season-previous year…    These all should be on the same time frame requirement and should be greater than 1 year – recommend 5 years (could be rolling – so updated every year), but needs to be greater than a single season/year in order to make sure you haven’t experience an anomaly – or you then have to write the additional rules around dealing with the anomaly

07 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.

• Last sentence should read, 'For the units required to do so, a Capability/ Operational Test...'

08 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.

No response submitted.

09 Please supply any comments related to the Resource Registration – Provision of Test Reports in the FS Submittal section.

• Should read, 'Test reports will be provided to the PO in the FS Submittal (BPM-108). QCC values for resources will be based on the Capability Tests and/or Operational Tests provided in the Forward Showing submittal.'

10 Please supply any comments related to the Resource Registration – Testing for Late Registered Resources section.

No response submitted.

11 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Background section.

No response submitted.

12 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Qualified Resources Included in FS Submittal That Have No QCC Previously Calculated section.

No response submitted.

13 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Thermal Resources section.

• Under 'Additional Thermal QCC Calculations Considerations (pg. 16) - 1st three bullt points - These are repeats from above
• Under 'Qualified Resources That Are Not Required to Report GADS Data' - Option 1 - Historial Output - 1st sentence - Why do we care about LLH?   Our monthly data would underestimate QCC b/c we load factor during LLH and choose to do scheduled maint during low load periods… (e.g. monthly average brought down because we choose to save water in LLH or do maintenance in LLH. ‘during CCH’  -- important note, only look at CCHs not a 744 average of both HLH and LLH

14 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Variable Energy Resources section.

• Pg. 20 - start of 2nd paragraph - Zonal Shapes - Point to Figure 3 & 4. Leave room in BP to update zones.   E.g. Solar on the East side of the cascades is not the same as west side solar.  

15 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Energy Storage section.

• Under 'Allocation of ELCC for ESRs (Pg. 26), 2nd sentence - Sentence feels confusing – ‘All’ feels like the wrong way to describe it, since a Two-Hour rated ESR doesn’t get the same rating.  Maybe something like – ‘ESRs across a Subregion will receive the average ELCC based on the ESRs hour rating (see above Four-Hour and Two-Hour rating descriptions)

16 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hybrid Facilities section.

No response submitted.

17 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Demand Response section.

No response submitted.

18 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hydro Resources section.

• 2ns paragraph (28), 2nd sentence - Wouldn’t using historical CCH generation be easier and more accurate? It is both – historical generation plus what was in storage behind the dam that we chose not to generate with at that time – theoretically we could have if it would have been needed, however we had already meet our need so didn’t need to generate additional that we could have,
• Pg. 29 ROR Hydro, last sentence - Why is this comment needed and underlined?  Previous we detail ways to get accreditation for new resources and such – why is this one singled out so boldly?

19 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Other Resources section.

No response submitted.

20 Please supply any comments related to Appendix A.

• General - Should reference this Appendix in areas above that talk about hydro - would prevent a lot of confusion.
• Time Period Approach for summer and winter season requirements (1st two sentences) - Perfect… why didn’t they say this before?   Confusing/conflicting text presented in body of BP.  (see areas where I commented above).

General Comment

DISREGARD - OUTDATED COMMENTS