01: Please supply any comments related to the Introduction, Definitions, or Background sections.
No response submitted.
02: Please supply any comments related to the Derivation of the CCH Analysis Components section (3).
No response submitted.
03: Please supply any comments related to the Derivation of the CCH Analysis Components - Load (Demand) section (3.1).
No response submitted.
04: Please supply any comments related to the Derivation of the CCH Analysis Components - Wind Resource Output section (3.2).
No response submitted.
05: Please supply any comments related to the Derivation of the CCH Analysis Components - Solar Resource Output section (3.3).
No response submitted.
06: Please supply any comments related to the Derivation of the CCH Analysis Components - Run of River Output section (3.4).
No response submitted.
07: Please supply any comments related to the Derivation of the CCH Analysis Components - Interchange section (3.5).
3.5 Regional Interchange
PNM questions the necessity to include Net Regional Capacity Need, i.e., Regional Interchange. PNM agrees with PacifiCorp “… it would be more appropriate for capacity critical hours to be calculated from the WRAP region’s gross load and each WRAP participant’s variable energy resource performance…”
And also with BPA, “Our thinking is that Regional Interchange may be appropriately shifting/extending the CCH given interchange flows are a function of RT price. Shifting/extending the CCH affects resource QCC values and entities ability to meet PRM.”
Could it be argued potential interchange is already captured in the “Contracts” section of the Forward Showing?
Lastly, reading the BPM it states, “Consequently, the Program Operator uses the previous ten Years of regional interchange data from the Northwest Power Pool Reserve Sharing Group (RSG)…”. Is there any data being used for determining the SWEDE interchange, as many SW entities were not participants in the NWPP RSG?
08: Please supply any comments related to the Determining the CCHs section (4).
No response submitted.
General Comment
PNM appreciates the opportunity to comment on BPM 102