01: Please supply any comments related to the Introduction, Definitions, or Background sections.

No response submitted.

02: Please supply any comments related to the Uncertainty Factor section (3).

Will the PO communicate to the entities what percentage Uncertainty Factor was used for each Preschedule day?  For example, if the entire subregion in in an overall deficient condition and the PO determines the subregion is no longer deficient at 8.5%, will entities be told of the 8.5% adder to their load forecast?

Another concern, potentially, is Voluntary Holdback.  Should a surplus entity, become less surplus, following the Uncertainty Factor calculation performed at 03:45 PPT (The Uncertainty Factor to be utilized on the Preschedule Day is performed by the Program Operator 2 hours ahead of the Sharing Calculation run described in BPM 201 Operations Program Timeline.)  Will the entity have time to receive and review with Uncertainty Factor now included in time to make an adjustment to their Voluntary Holdback?

Lastly, will the PO perform any look back analysis to determine the effectiveness of the 10% Uncertainty Factor?  It may be a worthwhile exercise to determine if the 10% is too conservative, or not conservative enough.  Also, looking at how often the 0.5% down adjustments are triggered.  Also, looking at if a subregion gets to the 3% threshold, and if so, how often?

General Comment

PNM appreciates the opportunity to comment.