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

The “Forced Outage” definition references “generating units”.  Consistent with the tariff’s section 20.1.1, constrained firm transmission service rights are cited as a cause for Forced Outage.  SRP requests confirmation that the document’s definition of Forced Outage aligns with the tariff.  SRP requests clarity on what is intended to be captured in “generating units”, including whether Energy Storage Resources (sometimes called “Non-Generator Resources” in our region) are generating units.

02: Please supply any comments related to the Components of the Sharing Calculation equation section (3).

SRP’s comments for BPM 103 regarding an interest in parity between Demand Response treatment paths are also applicable for BPM 202.

SRP understands that consistent with section 20.1.1 in the tariff, the Δ Forced Outages list includes lost capacity from thermal resources and storage hydro resources, but does not include Energy Storage Resources (or Demand Response capacity resources).  SRP requests guidance for how the sharing calculation can include legitimate loss of capability reflected in a Participant’s Portfolio QCC resulting from forced outage of Energy Storage Resources.

03: Please supply any comments related to the Inputs from the Forward Showing Submittal section (4).

SRP request the WPP please confirm that Energy Storage Resource QCC and Demand Response capacity resource QCC are correctly omitted from Section 4.

04: Please supply any comments related to the Inputs from the Operations Program section (5).

SRP requests confirmation that the Program Operator’s evaluation of a Participant’s surplus or deficit status does not require forecasted hourly Energy Storage Resource output and Demand Response utilization as inputs from the Operations Program.

05: Please supply any comments related to the Inputs from the Operations Program - Load Forecast section (5.1).

SRP recommends the WPP provide a detailed criteria for acceptable load forecasting tools to ensure consistent and accurate load forecasting across all participants.

Additionally, SRP suggest the WPP provide clarity in regards to whether participants have flexibility of using multiple forecasting tools within a single season. Specifically, SRP would like to understand if participants can validate more than one forecasting methodology with the WRAP and switch between validated forecasts methodologies during the season, except during the preschedules days.

Consistent with SRP’s concerns and comments for BPM 103 regarding an interest in parity between Demand Response treatment paths, a Participant’s election to utilize the Demand Response load modifier treatment could be considered modification of inputs “with the intent of increasing a Participant’s access to Holdback Capacity in the Operations Program or limiting their requirement to provide Holdback Capacity in the Operations Program.” Such modifications could potentially impact the equitable distribution of obligations and benefits among participants.

06: Please supply any comments related to the Inputs from the Operations Program - Forced Outage Forecast section (5.2).

SRP understands that GADS is the Generator Availability Data System, though this section suggests that GADS is the Generation Availability Data System.

SRP understands that GADS now includes reporting of outage events for VER resources according to the GADS Solar Generation (GADS‐S) – Data Reporting Instructions 2024.  SRP requests confirmation that if forecasted VER output considers reductions for expected Forced Outages consistent with GADS reporting, this would be captured in the Δ VER Performance component rather than section 5.2.

The sentence concluding section 5.2 is ambiguous: “Any derate, outage, or transmission curtailment resulting in a reduction of generation capability for must take resources, shall not be accounted for and excluded from Forced Outage forecasts.”  SRP requests clarity on whether the phrase is equivalent to “shall not be accounted for and shall be excluded from Forced Outage forecasts” or “shall be neither accounted for nor excluded from Forced Outage forecasts”.

07: Please supply any comments related to the Inputs from the Operations Program - Forecasted ROR section (5.3).

No response submitted.

08: Please supply any comments related to the Inputs from the Operations Program - Forecasted wind output section (5.4).

No response submitted.

09: Please supply any comments related to the Inputs from the Operations Program - Forecasted solar output section (5.5).

No response submitted.

10: Please supply any comments related to the Inputs from the Operations Program - Contingency Reserves Obligation section (5.6).

No response submitted.

11: Please supply any comments related to the Inputs from the Operations Program - Uncertainty Factor section (5.7).

SRP suggests the WPP ensure there is not a discrepancy between BPM 202 and BPM 203 regarding the Uncertainty Factor. BPM 202 does not specify a precentage, while BPM 203 states it should be set at 10% and can be decreased as low as 3% if the region is deficient. Including relevant information of the Uncertainity Factor in BPM 202 may ensure critical information is readily available for participants.

12: Please supply any comments related to the Input Data Files section (6).

No response submitted.

13: Please supply any comments related to the Input Data Files - Multi-Day file section (6.1).

No response submitted.

14: Please supply any comments related to the Input Data Files - Operating Day file section (6.2).

No response submitted.

15: Please supply any comments related to the Input Data Files - Point Limit file section (6.3).

No response submitted.

16: Please supply any comments related to the Input Data Files - Point to Point Limit File section (6.4).

No response submitted.

17: Please supply any comments related to the Input Data Files - Voluntary Holdback File section (6.5).

No response submitted.

18: Please supply any comments related to the Input Data Files - Actuals file section (6.6).

No response submitted.

19: Please supply any comments related to the Calculation of Sharing Results section (7).

SRP requests examples of how Δ ROR Performance and Δ VER Performance will be calculated “relative to the QCC of that Qualifying Resource”, as the QCC of a Qualifying Resource is an annual value but these Performance Adjustments are calculated hourly.

To facilitate understanding, SRP request the WPP identify what Performance Adjustment would be applied if a VER resource with a QCC of 25 MW is expected to have output of 100 MW for the relevant hour during the Forward Showing calculations but only expected to have 50 MW for the relevant hour during Operations Program calculations.

20: Please supply any comments related to the Planned Outages section (8).

No response submitted.

21: Please supply any comments related to Appendix A - Data Attestation

SRP seeks additional clarity on when this attestation is required and how it will be submitted.

General Comment

SRP appreciates the opportunity to comment on BPM 202.

SRP seeks further discussion to clarify how Energy Storage Resources, including unanticipated outages associated with Energy Storage Resources, may influence Sharing Calculations.