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).

1.  Do real-time prices and resulting flows of energy across interchanges in the operational window belong in the calculation of CCH used in the FS workbook requirements?  Would like to see the impact of removing Regional Interchange from the calculus of CCH.   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.     

Also worth considering that interchange flow values are BAA flows (page 7).  They are not necessarily reflective of WRAP LRE loads w/in the BAA.   Interchange flows could be driven by price arbitrage in the EIM or generator imbalance w/in the BAA that has nothing to do with loads in WRAP. 

2.  Section 3.5 doesn’t describe a methodology of how the program should look at the 10 years of historical data, identifying specific drivers and how they affect the overall period.  There is not a methodology to address adjustments to loads/resources based on that overall assessment, rather it discusses a specific period of time and the exact drivers that go into a set of years, as compared to another specific set of years.  It then says those drivers will not change for the next 5 years as a result of using this calculation, with these specific adjustments based on hour 19 regardless of what new data says.  This BPM should describe what drivers should be looked for that warrant adjustments.  The calculations for the data should be made each year that new data is submitted, and not tie the programs hands to a methodology outlined in this BPM for the next 5 years based on a historical assumption of change.  The loads and resources are changing rapidly (why WRAP was developed) and BPA feels the BPMs should not tie the hands of the program by only considering the current state.

3. Section 3.5.2 specifically calls out year 2018 through 2027, but what happens after 2027? Does that require updates to the BPM?  The BPM should discuss the methodology employed and not give specific periods except when using examples.  2023-2027 are future periods that current analysis doesn’t account for and we need to consider what happens if it shows significant change? We already know that the most recent period of time has significant interchange into the MidC region for a long period, that will change the assumptions described.  The BPM unecessarily locks down how the calculation is not based on assumptions and drivers but based on years, which feels shortsighted.  BPA suggests reconsideration/discussion of a better methodolgy.

4. Section 3.5.3 BPA notes the following:

• Historical Scarcity prices: RT scarcity prices most often are a function of outages or Force Majeaure (unpredictable/random). Folding them into routine CCH calculations (as capacity that is not available) is likely to skew the resulting CCH and PRM. Suggest removing Scarcity event availability assumptions b/c they are likely random.
• BPM states that it is using CAISO market clearing heat rates (price of energy/price of natural gas). BPM should indicate which price index/node is used in the calculations.
• BPM indicates that it is including a 2013 carbon adjustment of $6 applied to California market price before determining the market clearing heat rate. BPA suggests makign provisions in the BPM that allow this value to be updated annually.

08: Please supply any comments related to the Determining the CCHs section (4).

No response submitted.

General Comment

Thank you.