01: Please supply any comments related to the Introduction, Definitions, or Background sections.
In the sentence “The FSPRMs are applied to the P50 load forecasts of each Participant to set the FS Capacity Requirement for each month of a Binding Season” in the Introduction, this should probably read "for each Participant" instead of "of each Participant" because Participants don't provide the forecast.
In the Definitions section for the Cure Deadline the definition says it is 120 days after the FS Deadline, however; there is 122 days between March 31 (FS Deadline) and July 31 (Cure Deadline) for the Winter Season. Should this definition just say the dates of the Cure Deadline which are July 31st and February 28th (leap year impacts?). I have a similar comment for the definition of Cure Period as well, to remove the 120 days time period and just use the dates, or just the time period between the FS Deadline and Cure Deadline could be the definition.
02: Please supply any comments related to the Forward Showing Submittal and Cure Period section (2).
No comments at this time.
03: Please supply any comments related to the Forward Showing Submittal Materials section (3).
No comments at this time.
04: Please supply any comments related to the Forward Showing Submittal Materials - FS Demonstration section (3.1).
No comments at this time.
05: Please supply any comments related to the Forward Showing Submittal Materials - Loads section (3.1.1).
No comments at this time.
06: Please supply any comments related to the Forward Showing Submittal Materials section - Qualifying Resources section (3.1.2).
In the section referring to Catastrophic Resource Failure Exception it is unclear what occurs if the exception is granted. If this handled in a separate BPM then please add a reference to it, otherwise, please explain how this impacts the resources a participant is required to bring.
07: Please supply any comments related to the Forward Showing Submittal Materials - Contracts section (3.1.3).
No comments at this time.
08: Please supply any comments related to the Forward Showing Submittal Materials - Transmission section (3.1.4).
APS thinks this could be better clarified to reflect the expectations of Participants. Particularly, the sentence, “The FS Demonstration shall include information on the Participant’s transmission service reservations that it reasonably plans to utilize in the upcoming Binding Season.” - Is it all reservations or only those used to meet the 75% that a Participant should include in the Transmission section of the FS? Also, "shall include" followed by a Participants judgment of "reasonably plans to utilize" is confusing.
In section 3.1.4.1.1 Enduring Constraints there is discussion around constraints around segments. APS is interested in what the definition of segment is, and why is it segment, or is it a single POR/POD combination? A POR/POD combination can be made up of multiple segments, and segment has a specific meaning on OASIS for transmission reservations, so want to make sure if we are intending align with the use of segment on OASIS, or is segment defined by WRAP independently. For section 3.1.4.1.3 Transmission Outages and Derates APS is wondering if we need to report this exception or any exception possibility in the instance where the 75% FS transmission requirement is met? Our belief is no exception information is needed if a Participant meets the 75% FS threshold, is that accurate and if so, can we explicitly mention that in the BPM?
In section 3.1.4.1.4 Counterflow of a Qualifying Resource the last paragraph states, “Counterflows that involve three or more BAAs as sources and sinks will not qualify for the Counterflow of a Qualifying Resource exception.”. APS believes that it is not possible to have more than 2 BAAs as sources/sinks, so this situation of having 3 or more as sources/sinks is not possible and propose deleting “…as sources and sinks…”.
09: Please supply any comments related to the Forward Showing Submittal Materials - Planned Outages section (3.1.5).
In general, APS is wondering why we are concerned about the status of a resource at FS Deadline? The FS is for months 7 months away, why don't we focus on the status of resources in the Binding Season? Much of the section discusses a scenario where a resource is unavailable at the time of FS, rather than discussion how to account for and submit planned outages that are known at the FS Deadline.
Also, APS has previously communicated planned outage representation in the FS should be reflective of the highest day of planned outages in the month. APS supports the following language be added to this section to capture this aspect. “For the highest day of cumulative planned outages in a month during a binding season, any planned outages taken on resources will result in the QCC of those resources being reduced to zero for the month. Highest day of cumulative planned outages in a month shall be calculated as the highest sum of QCC for resources on planned outage for each day of the month.” APS disagrees with the language in the BPM that states, “Participants shall provide information on all Qualifying Resources that are planned to be out of service during the Binding Season in their FS Demonstrations as part of their FS Submittal…”, as this should only be required if the outage is planned during the highest day of cumulative planned outages. APS strongly believes you can't count all outages on all Qualifying Resources that don't overlap in the month as unavailable for meeting the FS Requirements.
10: Please supply any comments related to the Forward Showing Supporting Materials section (3.2).
No comments at this time.
11: Please supply any comments related to the Forward Showing Supporting Materials - Testing section (3.2.1).
Is the resource testing form available that is mentioned in this section, and what is the need to have a different form than the FS Workbook to submit the testing information?
12: Please supply any comments related to the Forward Showing Supporting Materials - Thermal Resources that are not Required to Report GADS Data section (3.2.2).
APS wonders if this Attestation could be made available for all resources that don’t have GADS data available, rather than limited to Thermal Resources that are not required to report GADS data. It seems odd that a Participant can only submit equivalent data when GADS is not required, rather than being able to submit and attest to the data in place of GADS data. If this section needs to continue as being only for resources that aren’t required to report GADS data, the criteria or link to the criteria for GADS requirements would be helpful.
13: Please supply any comments related to the Forward Showing Supporting Materials - Hydro Resources section (3.2.3).
No comments at this time.
14: Please supply any comments related to the Forward Showing Supporting Materials - Late Registered Resources section (3.2.4).
No comments at this time.
15: Please supply any comments related to the Forward Showing Supporting Materials - Transition Exceptions section (3.2.5).
In section 3.2.5.1 it states, “To obtain an ETD for a Binding Season, the Participant must provide a Senior Official Attestation as part of their FS Submittal,…’ Is this necessary, what if a Participant is found deficit by the PO after FS submission? That entity then can't get an ETD on the deficiency since it didn't submit this attestation at FS Deadline. Should we amend to say they must submit this if applying for ETD as part of FS Demonstration, but they can also receive an ETD if they are found to be deficit after the FS Deadline and submit the needed information for an ETD.
16: Please supply any comments related to the Cure Period section (4).
The table in Table 2 is the same as the table in Table 1 of the BPM, we would propose removing one of them and referencing the remaining table in the section it is removed from.
17: Please supply any comments related to Appendix A.
No comments at this time.
18: Please supply any comments related to Appendix B.
No comments at this time.
19: Please supply any comments related to Appendix C and D.
In Appendix D – Enduring Constraint Attestation it states, “[Participant] has posted Firm Transmission Requirements on the relevant bulletin board, i.e.,” APS is not familiar with posting of "Firm Transmission Requirements" – Can we expand on what this means in Appendix D further?
20: Please supply any comments related to Appendix E.
Only attest to ones currently out of service and not the ones that may be out of service in the Binding Season???? It also conflicts with the reference above in the BPM to Appendix E being used to attest that outages won’t be greater than surplus if planned outage information is not available. That could happen even with resources that are currently in service.
Why do replacement resources for those that are on outage have to be located in same place? What is the location attribute referenced (state,region)?
21: Please supply any comments related to Appendix F.
Does performance data cover both historical production and outage information? It needs to be based on the 2 methods available for non-GADS QCC determination.
22: Please supply any comments related to Appendix G.
In calculating Portfolio QCC, APS believes that the formula has the wrong use of planned outages as commented on by APS in question #9 of this comment template. APS strongly believes you shouldn’t consider every unit on outage in the month they don't overlap and are not on outage on the highest cumulative day of planned outages in the month.
General Comment
For Appendix H, wouldn't this attestation best be done at the Advance Assessment data submittal rather than at the FS submittal? It would be preferred to notify a Participant that if they include DR impacts in historical loads submitted for the Advance Assessment and subsequently try and get credit for the DR program in the FS they can't. Also, there should be some way to remedy this situation and allow the DR to be shown in the FS even if the load was after DR was deployed in the historical loads submitted.