01: Please supply any comments related to the Introduction, Definitions, or Background sections.
No response submitted.
02: Please supply any comments related to the Calculating the Deficiency Charge section (3).
No response submitted.
03: Please supply any comments related to the Calculating the Deficiency Charge - Calculating the Deficiency section (3.1).
The figure Header says 'Monthly Capacity Deficiency' and the statement below says 'Monthly Deficiency'. We suspect they coincide and are supposed to be the same thing, and one of the two titles needs to be udpated. LIke to 'Monthly Deficiency.'
04: Please supply any comments related to the Calculating the Deficiency Charge - Calculating the Deficiency Charge section (3.2).
1. BPA suggests for consideration naming the formulas appropriately as "formula 1, 2, 3, and 4" are not descriptive or helpful in conversations.
2. BPA believes we should look closer at the formulas as they pose concerns. We believe the objective of the CONE penalty is to send a very specific signal to participants to acquire the needed capacity to meet the FS Requirement and just accepting the penalty is not a financial alternative. We are concerned that it is sending a different punitive message, which could cause participants to not want to participant in the program. Base assumption is that capacity is available (physical resource and or transmission), in todays world that may not be an appropriate assumption between given huge potential load groth, constrainted transmission systems (and interconnections) and resource aquisition, it is possible for loads to come on-line faster than infrustructure can support. Current BPM methodology doesn’t support this issue or acknowledge it. Causing Cone penalties to be excessively punative: Max month penalties (1&3) include Annual CONE charges based on full year costs, additional months of deficit include layered additive changes for every MW of deficit, even if already paid for under the max month annual Charge. This causes a layering effect for a deficit spanning multiple months in a season. Need to evaluate these possibilities and make potential adjustment to maintain the stiff penalty, but not make them excessively punitive.
05: Please supply any comments related to the Calculating the Deficiency Charge - Determining Certain Components of the Deficiency Charge Calculation section (3.3).
1. 3.3.1: Changes to the Cone need more details than what is currently captured. The Cone factor that will be used in the assessment of a charge due to a deficiency in Forward Showing needs to be posted prior to the submission deadline. That is the cone charge that will be used for that filing. The next seasons change could be different, but also posted and associated with that Forward Showing filing.
2. 3.3.2: The final paragraph indicates Non-zero Summer % Deficit or Winter % Deficit --- and the immediately following ……. Shall be 200%. Doesn’t the described factors for both summer and winter establish the factor any time someone has a deficit? Or is this saying that if the program is good and then someone experiences a deficit that we imediately go to the maximum factor for a season? That seems like an excessive penalty, when we already have a structure in place to determine the factor.
06: Please supply any comments related to the Timing of Deficiency Charge Revenue Collection section (4).
No response submitted.
07: Please supply any comments to the Allocation of Revenues from Deficiency Charges section (5).
No response submitted.
08: Please supply any comments related to the Board Appeal Process section (6).
No response submitted.
General Comment
Thank you.