COMMENT FOR BPM 202 - Participant Sharing Calculation Inputs

Submitted July 30, 2024, 12:46 p.m.





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 Components of the Sharing Calculation equation section (3).

No comments at this time.

03: Please supply any comments related to the Inputs from the Forward Showing Submittal section (4).

No comments at this time.

04: Please supply any comments related to the Inputs from the Operations Program section (5).

No comments at this time.

05: Please supply any comments related to the Inputs from the Operations Program - Load Forecast section (5.1).

No comments at this time.

06: Please supply any comments related to the Inputs from the Operations Program - Forced Outage Forecast section (5.2).

APS believes that are valid GADS codes are not applicable to capturing of forced outages and derates, can we add the applicable GADS types here to be utilized? For example, U1 and D1 are outage and derate immediate GADS codes where PO is a planned outage and shouldn’t be included in the data files submitted by participants.

 

For the note on must take thermal resources is it not possible a participant submitted historical data to calculate a EFOF, therefore could submit the forced outages associated with the resource in the Operations Program in that scenario?

07: Please supply any comments related to the Inputs from the Operations Program - Forecasted ROR section (5.3).

No comments at this time.

08: Please supply any comments related to the Inputs from the Operations Program - Forecasted wind output section (5.4).

No comments at this time.

09: Please supply any comments related to the Inputs from the Operations Program - Forecasted solar output section (5.5).

No comments at this time.

10: Please supply any comments related to the Inputs from the Operations Program - Contingency Reserves Obligation section (5.6).

No comments at this time.

11: Please supply any comments related to the Inputs from the Operations Program - Uncertainty Factor section (5.7).

No comments at this time.

12: Please supply any comments related to the Input Data Files section (6).

No comments at this time.

13: Please supply any comments related to the Input Data Files - Multi-Day file section (6.1).

No comments at this time.

14: Please supply any comments related to the Input Data Files - Operating Day file section (6.2).

No comments at this time.

15: Please supply any comments related to the Input Data Files - Point Limit file section (6.3).

No comments at this time.

16: Please supply any comments related to the Input Data Files - Point to Point Limit File section (6.4).

No comments at this time.

17: Please supply any comments related to the Input Data Files - Voluntary Holdback File section (6.5).

This sections says VH can only be provided if the Participant is in surplus in the sharing calculation, is that a valid constraint on the Participants seeking to offer voluntary supply or is it allowable for a deficit entity to provide VH?

18: Please supply any comments related to the Input Data Files - Actuals file section (6.6).

No comments at this time.

19: Please supply any comments related to the Calculation of Sharing Results section (7).

No comments at this time.

20: Please supply any comments related to the Planned Outages section (8).

This section is silent on construction delays related to resources expected to be available and shown in the Forward Showing, but then are delayed in the Operations Program. How should such delay be communicated in regards to being a planned or forced outage?

21: Please supply any comments related to Appendix A - Data Attestation

It’s unclear when the attestation will be performed if it is before the season the language should be worded as pretense, as written it is past tense implying it is done after the season, but APS doesn’t see the cadence of the attestation within the BPM and requests it to be added.

General Comment

No comments at this time.

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