01: Please supply any comments related to the Introduction, Definitions, or Background sections.
None
02: Please supply any comments related to the Forward Showing Submittal and Cure Period section (2).
A "PM" was likely omitted from the section. A deadline of 05:00 for the Forward Showing Submittal seems out of place. 17:00 or some other time during normal business hours seems more appropriate.
03: Please supply any comments related to the Forward Showing Submittal Materials section (3).
None
04: Please supply any comments related to the Forward Showing Submittal Materials - FS Demonstration section (3.1).
None
05: Please supply any comments related to the Forward Showing Submittal Materials - Loads section (3.1.1).
None
06: Please supply any comments related to the Forward Showing Submittal Materials section - Qualifying Resources section (3.1.2).
None
07: Please supply any comments related to the Forward Showing Submittal Materials - Contracts section (3.1.3).
PAC will look forward to the opportunity to review and comment upon BPM 106, once published. PAC anticipates WPP will address the JCAF requirement within BPM 106.
08: Please supply any comments related to the Forward Showing Submittal Materials - Transmission section (3.1.4).
None
09: Please supply any comments related to the Forward Showing Submittal Materials - Planned Outages section (3.1.5).
PAC would appreciate additional clarity in this section in regard to how planned outages affect resource QCCs in the Forward Showing.
PAC is lead to understand by the language of this section any planned outage for a resource lasting five or more days reduces the resource's QCC to zero for the given month in the Forward Showing.
The following passage implies potential different treatment for resources offline at the time of Forward Showing submittal whose outages will extend into the binding season, versus resources available at the time of FS submittal but with planned outages overlapping with the binding season. The passage does not clearly address the latter these implied categories, into which most planned outages would likely to fall:
"Any Qualifying Resource that is out of service at the time of the FS Deadline and is planned to remain out of service for five or more days of a month in the Binding Season cannot have such Qualifying Resource’s QCC counted toward meeting the Participant’s FS Capacity Requirement for that month"
PAC would suggest a resource QCC reduction proportional to expected resource availability during the binding month, instead of the all-or-nothing approach of this BPM. PAC would prefer something like a "planned outage factor" to apply to the monthly QCC. This would be calculated and applied as follows: (# of days resource is available / # of total days in month) * QCC.
PAC further notes planned outages are often intended to be contained to shoulder months, but personnel, parts or schedule availability may force planned outages to be scheduled into the the early weeks of June or November, when RA risk is generally low.
10: Please supply any comments related to the Forward Showing Supporting Materials section (3.2).
PAC would appreciate any forms required in the Forward Showing to be included as appendices to the BPM. The form itself may impose requirements not mentioned in the parent BPM or WRAP tariff. By leaving the forms out of the BPM, requirements can be imposed, and modifications to the forms can potentially be made outside of a governance or review process.
11: Please supply any comments related to the Forward Showing Supporting Materials - Testing section (3.2.1).
None
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).
None
13: Please supply any comments related to the Forward Showing Supporting Materials - Hydro Resources section (3.2.3).
None
14: Please supply any comments related to the Forward Showing Supporting Materials - Late Registered Resources section (3.2.4).
None
15: Please supply any comments related to the Forward Showing Supporting Materials - Transition Exceptions section (3.2.5).
None
16: Please supply any comments related to the Cure Period section (4).
None
17: Please supply any comments related to Appendix A.
None
18: Please supply any comments related to Appendix B.
None
19: Please supply any comments related to Appendix C and D.
None
20: Please supply any comments related to Appendix E.
None
21: Please supply any comments related to Appendix F.
None
22: Please supply any comments related to Appendix G.
None
General Comment
PacifiCorp appreciates the work of the WPP on BPM 108, and is grateful for the opportunity to comment.