01: Please supply any comments related to the Introduction, Definitions, or Background sections.
No response submitted.
02: Please supply any comments related to the Forward Showing Submittal and Cure Period section (2).
"at 05:00 Pacific Prevailing Time (PPT) on the date indicated. The Program Operator shall serve"
So we are saying 5AM and not 5PM (or COB) on that date?
Believe this should be 5PM or 1700 hours.
03: Please supply any comments related to the Forward Showing Submittal Materials section (3).
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).
"Participants shall document all loads in their FS Demonstration, including excluded load"
Including 'excluded load' - how/were do you excluded load?
"Subregion with the lower monthly FSPRM to the load in the Subregion with the higher monthly FSPRM"
Why is the single workbook requirement, to provide transmission from lower FSPRM to Higher PRM. A participant may not care about the lower FS PRM but wants a single system and be willing to use the higher PRM because that is the subregion were resource are located.
This rule of using a single workbook should be expanded to ALL conditions
"In accordance with this, a Participant may be required to submit separate FS demonstrations, even as to loads residing in the same Subregion"
Hard to forward contract with this uncertainty combined with uncertainty associated with CCH and PRM which change each season and each year and which are also subject to sole discretion of PA. Seems like we need some sort of pre-FS consultation process to avoid surprises/fines.
If This determination is made after FS Submittal, it should be for future seasons, and not a deficiency in the current submittal process
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).
3.1.4.1. Transmission Exceptions
- Future Firm ATC [available transmission capability] Expected";
Second and third bullets were run together on the same line.
"All Participants requesting a Monthly Transmission Exception are responsible for submitting the completed Transmission Exception request form found on the WPP "
Include either link to the form or the actual form as part of the Appendix C.
"by 05:00 PPT on the 60th day after the FS Deadline."
Again 05:00 is 5am
"the Participant has acquired a different resource with the necessary firm transmission and no longer requires the Monthly Transmission Exception."
Does the replacement resource notification require a QCC? Or to meet standard contract requirements for establishing QCC through a JCAF - seems to be missing?
"If a Monthly Transmission exception is denied (either because it is invalid or because circumstances changed and transmission has become available during the review period),"
What if deemed 'invalid' and therfore denied after cure period?
In the described example (above) Future period would be February 28th, what if WPP determines the monthly check-in is denied in March - does a participant have 30 days to rectify before being assessed a failure charge?
Participant should ALWAYS receive time to solve a problem before receiving a charge, after an initial acceptance/approval of an exemption, and filing a monthly check-in, and receiving a Denied notification.
3.1.4.1.1. Enduring Constraints
"any single segment of a source-to-sink path for a resource (exceptions will not be granted for two segments of a source-to-sink path)"
Is this new? Do not recall the single segment restriction. There will likely be situations where two segments have constraints and no available firm transmission. Consider allowing multiple segment exceptions.
"for all CCHs in the most recent same season from the most recently available CCH data set;"
'Most Recent' shouldn’t this be the CCH used for the analysis/determination/ Forward Showing submittal…. If a new set of CCH's are released 30 days before a FS deadline, Participants cannot be expected to adopt new CCH's and incorporate them in all submittal functions.. Exemptions could take months of leg work to pull together, changing the CCH's at short notice should facilitate the use of previous. Sr official Attestations will require that FS submittals are complete well ahead of due date in order to get approvals.
09: Please supply any comments related to the Forward Showing Submittal Materials - Planned Outages section (3.1.5).
No response submitted.
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).
"all Qualifying Resources"
Do we need to footnote that hydro does not require annual Operational tests?
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).
The formatting of this paragraph was a little goofed up.
16: Please supply any comments related to the Cure Period section (4).
Table 1 and Table 2 are identical. This table only needs to be shown once.
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.
Planned Outage Attestation -
This attestation forces parties to account for scheduled outages in the FS Submittal.. Discussion has always been that a party could 1) enter outages, thereby reducing QCC values, or 2) attest that outages will be taken out of surpluses and therefore not enter outages..
This seems to be a change in that second concept..
Believe it needs a second part of attestation to identify that - all scheduled outages will be taken from surpluses!
21: Please supply any comments related to Appendix F.
No response submitted.
22: Please supply any comments related to Appendix G.
FS Summary feels very prescribed.. By including it here (in the BPM) it creates a requirement of how it is laid out! Would suggest that this appendix should include the components of what the bare minimum included in the FS Summary is, rather then how it is laid out, simply a list of the components the summary must include.
"Total Portfolio QCC"
Shouldn’t this say the Participant’s demonstrated FS Transmission rather than their Total Portfolio QCC? Our understanding is that CC does not measure transmission.
General Comment
See BPA comments attached