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

No comments at this time.

02: Please supply any comments related to the Uncertainty Factor section (3).

APS believes the BPM is unclear currently whether the Program Operator or Participants can have differing uncertainty values than the sub-region. Is the 0.5% always applied to the full sub-region or can uncertainty values differ among a sub-region by either Participant request to reduce or Program Operator request. APS would also like to understand better how the deficit entities are considered when reducing the uncertainty of the entire sub-region, a reduction in a deficit entities uncertainty component of the sharing calculation would result in them being considered less deficit, is this the intent of the 0.5% reductions, or is the reduction in uncertainty only applicable to surplus entities so that more surplus is available to the same level of deficit?

General Comment

No comments at this time.