01: Please supply any comments related to the Introduction, Definitions, or Background sections.
No response submitted.
02: Please supply any comments related to the Study Scoping Process section (3).
No response submitted.
03: Please supply any comments related to the Load and Resource Zones section (4).
No response submitted.
04: Please supply any comments related to the Load and Resource Zones - Subregions Used for Determination of Monthly FSPRMs section (4.1).
No response submitted.
05: Please supply any comments related to the Load Modeling in the LOLE Study section (5).
1. BPA noted Table 1 is not identified or described in the document - it seems to be added without context. The title describes it as Example Historical Weather Stations, but BPM does not describe what Station#1 or Station #2 means?
Section 5 references a 'Table 3' that doesn’t seem to exist in the documents but may be referencing Table 1, but it identifies 4 weather stations and corresponding back-up weather stations. If that is supposed to reference Station #1 and #2, the language should be cleaned up to match.
If Station 1 and 2 is not primary and backup, the closeness of stations will serve to throw off averages for the region, as backups they work.
2. There is only a short description of how the 40 annual load shapes will be created but BPM lacks either detail or examples (or both) of how this will be done. A single paragraph describing the entire process of the load shapes used to establish participant loads and PRMs seems a little on the abbreviated side, especially given that the timing of publication and calculation of these numbers are within participants 2 year exit period. This is insufficient description of how loads are built.
06: Please supply any comments related to the Generator Modeling in the LOLE Study section (6).
1. 6.0: Missing a word in the last sentence: "needed to meet the reliability metric each month will then be converted to unforced capacity (UCAP) values (see Section 9) to calculate the FSPRMs (as a percentage)."
2. 6.1: The description of EFORd for Thermals does NOT correspond to the EFOFcch description used in BPM 105 (section 4.2). BPM 105 describes using 6 years of data, and removing the worst year. Concern of why would we utilize a totally different methodology and philosophy in the calculation of EFORd? It seems that dropping the worst year of 6 in one type of calculation is valid, but why would it not be valid in the other? Consistency is important here.
Table 2 of the BPM also calls out the use of Thermal QCC as defined in BPM105, again causing an inconsistancy.
3. 6.3: Appears there may be a contradiction or there may need to be some clarification. “ Wind resources will be modeled together as a single wind resource per LRZ in the LOLE Study.” Vs Page 12 “Actual resource output will be used when available.” (assume actual resource data is included in the LRZ study?)
4. 6.4: Section is on solar resources, but appears maybe a copy/paste error as this indicates wind "The PO will identify in the Study scope whether synthesized wind shapes for years where historical data …. “
May also need to inquire/make consideration for that highly accurate solar radiance studies for BPAT should be available in the NREL data set, others BA's may also be contracting for higher accurate studies and making data available. Consider including in the BPM that more accurate data can be used from other sources, but NREL data will be the base level.
5. 6.5:
Deb Malin Comment: "Preserve Reliability mode - ESRs (Batteries) will only be discharged when there is a lack of other resources available.” Question if this assumption will stand the test of time, or if they will be used to serve load as a more cost effective resource in a future market environment. Suggest that the BPM leaves room and language to allow a change in that modeling assumption if/when the program sees ESR's consistently operating in another fashion. Providing language allow the BPM to stand over time rather then requiring an update to include a different assumption in the modeling of LOLE.
07: Please supply any comments related to the Generator Modeling in the LOLE Study - Thermal Generator Modeling section (6.1).
No response submitted.
08: Please supply any comments related to the Generator Modeling in the LOLE Study - Storage Hydro Qualifying Resources section (6.2).
No response submitted.
09: Please supply any comments related to the Generator Modeling in the LOLE Study - Wind Resources section (6.3).
No response submitted.
10: Please supply any comments related to the Generator Modeling in the LOLE Study - Solar Resources section (6.4).
No response submitted.
11: Please supply any comments related to the Generator Modeling in the LOLE Study - Energy Storage Resources section (6.5).
No response submitted.
12: Please supply any comments related to the Generator Modeling in the LOLE Study - Run of River Qualifying Resources section (6.6).
No response submitted.
13: Please supply any comments related to the Generator Modeling in the LOLE Study - Demand Response Programs section (6.7).
No response submitted.
14: Please supply any comments related to the Generator Modeling in the LOLE Study - Behind-the-Meter Generation section (6.8).
No response submitted.
15: Please supply any comments related to the Generator Modeling in the LOLE Study - External Capacity Modeling section (6.9).
No response submitted.
16: Please supply any comments related to the Generator Modeling in the LOLE Study - Contingency Reserves Modeling section (6.10).
No response submitted.
17: Please supply any comments to the LOLE Study section (7).
No response submitted.
18: Please supply any comments to the FSPRMs Calculations section (8).
No response submitted.
General Comment
Thank you, also please note there are several spelling typos in the document that we did not capture specifically in our comments.