01: Please supply any comments related to the Introduction, Definitions, or Background sections.
Regarding page 4, “2. Forward Showing Submittal and Cure Period” should the 5:00 PPT time be 17:00 PPT (i.e. close of business)?
02: Please supply any comments related to the Forward Showing Submittal and Cure Period section (2).
No response submitted.
03: Please supply any comments related to the Forward Showing Submittal Materials section (3).
No response submitted.
04: Please supply any comments related to the Forward Showing Submittal Materials - FS Demonstration section (3.1).
No response submitted.
05: Please supply any comments related to the Forward Showing Submittal Materials - Loads section (3.1.1).
No response submitted.
06: Please supply any comments related to the Forward Showing Submittal Materials section - Qualifying Resources section (3.1.2).
No response submitted.
07: Please supply any comments related to the Forward Showing Submittal Materials - Contracts section (3.1.3).
No response submitted.
08: Please supply any comments related to the Forward Showing Submittal Materials - Transmission section (3.1.4).
Section 3.1.4.1
Should the 5:00 PPT time be 17:00 PPT (i.e. close of business)?
Section 3.1.4.1.2
Please consider clarifying the language for item 2 as follows “The Participant provides evidence that its transmission service provider has released additional NERC Priority 7 or 6 Firm PTP or network integration service in all of the CCHs in the most recent Summer or Winter Binding Season, as appropriate, on the applicable path following the FS Deadline;”
09: Please supply any comments related to the Forward Showing Submittal Materials - Planned Outages section (3.1.5).
The second paragraph of this section begins, “A Participant’s FS Demonstration shall include information on all Qualifying Resources that are out of service at the time of the FS Deadline that plan to return to service after the first five days of the Binding Season.” Whether the resource is offline at the time of the FS Deadline doesn’t seem relevant. The requirement should be that the FS Demonstration include information on any outages that are scheduled for any part of the binding season (regardless of whether the resource is offline at the time of the FS Deadline), and that any resource scheduled out for more than the first five days of a binding season cannot be counted for the first month of that season (assuming that is the intention of this section).
The third paragraph has a reference to outages “not yet begun at the time of the FS Deadline.” Again, the FS Deadline does not seem relevant here. Regardless of the start date of the planned outage, the requirement should be the same (i.e. if the outage extends beyond the first five days of a Binding season, the Capacity is deducted from the Participants resources).
Also in this section, the language does not specifically address planned or known transmission outages that affect the delivery of certain resources. Please consider adding language to address this situation.
10: Please supply any comments related to the Forward Showing Supporting Materials section (3.2).
No response submitted.
11: Please supply any comments related to the Forward Showing Supporting Materials - Testing section (3.2.1).
Consider adding additional detail regarding acceptable supporting documentation/evidence of generator testing. (BPM 105 describes the tests, but doesn’t specify the documentation that should be provided.)
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).
No response submitted.
13: Please supply any comments related to the Forward Showing Supporting Materials - Hydro Resources section (3.2.3).
No response submitted.
14: Please supply any comments related to the Forward Showing Supporting Materials - Late Registered Resources section (3.2.4).
No response submitted.
15: Please supply any comments related to the Forward Showing Supporting Materials - Transition Exceptions section (3.2.5).
Section 3.2.5.2
The section regarding contracts for which the Participant cannot obtain a JCAF is in the Transition Exceptions section. This implies that the No JCAF exception will only apply during the transition period. However, many Participants have legacy contracts that will be in place beyond the transition period. In these instances, the exception should be allowed to be permanent. For example, Participants have legacy PURPA contracts with terms of twenty or more years, in some cases with generators who may be unwilling to sign a JCAF. Further, the exception should apply to contracts executed after October 1, 2021 in cases where the Participant is unable to require the seller to execute a JCAF. Again, this can be the case with PURPA contracts, where the utility is required to purchase the output from the facility but has limited ability to impose additional requirements beyond the PPA.
16: Please supply any comments related to the Cure Period section (4).
This section is essentially a repeat of Section 2, including the table. Suggest deleting this section and including any necessary language in Section 2 to avoid reduncy and potentially conflicting language.
17: Please supply any comments related to Appendix A.
No response submitted.
18: Please supply any comments related to Appendix B.
No response submitted.
19: Please supply any comments related to Appendix C and D.
No response submitted.
20: Please supply any comments related to Appendix E.
The language in this attestation seems redundant. The attestation in Appendix A addresses the truth and completeness of the FS Demonstration. A separate attestation with regard to planned outages is not necessary. (If necessary, the language in Appendix A could be expanded, but not to the level of detail currently included here.)
Additionally, this appendix includes language (addressed earlier in NorthWestern’s comments) regarding resources that are currently out of service. Again, whether a resource is out of service at the time of the showing isn’t relevant to the binding season occurring seven months in the future, and it makes the language more complicated than it needs to be. The key is to require all know outages to be submitted (either planned, or unplanned with a return to service date during or after the upcoming binding season).
21: Please supply any comments related to Appendix F.
No response submitted.
22: Please supply any comments related to Appendix G.
Minor point - this appendix seems out of order relative to the attestations in appendices H and I, which seem more appropriately grouped with appendices A through F.
General Comment
NorthWestern appreciates the work from WPP and SPP staff and others in devloping this BPM. Thank you for the opportunity to comment.