01: Please supply any comments related to the Introduction, Definitions, or Background sections.
No response submitted.
02: Please supply any comments related to the Contracts Eligible for QCC value section (3).
No response submitted.
03: Please supply any comments related to the Contracts Eligible for QCC value - Resource-Specific Capacity Agreements section (3.1).
No response submitted.
04: Please supply any comments related to the Contracts Eligible for QCC value - System Sale section (3.2).
NV Energy does not understand what is meant by the reference to provide additional transmission in the Forward Showing in order to meet the transmission requirement. Specifically, would it be possible to count the contract capacity towards the Forward Showing without the transmission path known at the time of the Forward Showing demonstration with an assurance that it will be secured using firm transmission rights? NV Energy argues that an assurance that firm transmission will be secured prior to the operational program should be sufficient as long as the participant can meet their 75% transmission requirement in the Forward Showing.
Section 3.2.2 provides additional detail for the requirements that are needed for a system sale to qualify towards meeting the Forward Showing, however, this section does not indicate if there is a cap or a quantity limit of the amount that could be purchased and applied towards the participant buyers Forward Showing. This section should also specify whether or not any limits exist for purchases of a system sale.
05: Please supply any comments related to the Joint Contract Accreditation Forms section (4).
NV Energy does not understand the difference between the resource specific delineation in Table 1 of the 100% off take or must take contracts. If a resource is contracted 100% to a participant, then that resource should be credited towards the participants Forward Showing without the requirement to fill out a JCAF. A contract that includes a provision where the participant may decide not to take all of the energy would likely occur during instances of oversupply conditions and should not hinder the reliability of this program. The requirement to sign a JCAF by both the participant and the seller of a resource that is registered in the program and 100% contracted to that participant is excessive and administratively burdensome considering the participant has to attest to all information supplied in each Forward Showing. Therefore, NV Energy does not support the requirement to fill out a JCAF for a resource that is 100% contracted to supply the participant buyer. Furthermore, NV Energy does not support the requirement to submit a JCAF for each resource specific contract that is less than 100% off take for each Forward Showing season. Resources that are registered with the program should not have to go through the extra burden of submitting a JCAF.
Section 4 also requires a participant to provide a signed JCAF for sales to non-participants. NV Energy does not understand the reasoning for this. The program requires the participant to list all purchases and sales in the Forward Showing with an attestation, therefore, it is not clear why an additional JCAF form is required. NV Energy does not support this requirement when a participant sells to a non-participant.
06: Please supply any comments related to the Calculating Net Contract QCC section (5).
No response submitted.
07: Please supply any comments related to the Resource Adequacy Transfers (RA Transfers) section (6).
No response submitted.
08: Please supply any comments related to Appendix A.
No response submitted.
09: Please supply any comments related to Appendix B.
No response submitted.
10: Please supply any comments related to Appendix C.
No response submitted.
11: Please supply any comments related to Appendix D.
No response submitted.
General Comment
NV Energy appreciates the opportunity to comment on BPM 106 and offers additional general comments to gain additional understanding about the types of contracts that will qualify towards meeting a participant Forward Showing requirements. NV Energy believes the following questions should be addressed somewhere in this BPM:
- How many hours should be procured to qualify towards meeting the Forward Showing requirement? For instance, does a participant need to procure supply for all hours of the month or do they only need to procure supply needed during the capacity critical hours? Additionally, would a super peak product qualify towards meeting the Forward Showing requirement at a percentage of the contracted amount if not all the capacity critical hours were procured?
- Can the contract state that the resource may not be needed during times of low loads when excess cheap supply exists or will the resource be required to be dispatched for all hours of the month to be applied towards the Forward Showing? NV Energy argues that a contract should be allowed to not be needed when loads are low and excess cheap supply exists otherwise this capacity would require participants to over procure during low load periods.