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).
No response submitted.
03: Please supply any comments related to the Forward Showing Submittal Materials section (3).
No response submitted.
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).
No response submitted.
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).
No response submitted.
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).
No response submitted.
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).
No response submitted.
16: Please supply any comments related to the Cure Period section (4).
No response submitted.
17: Please supply any comments related to Appendix A.
To be consistent with the previous sentence, Powerex suggests adding the underlined to the sentence: “I further attest, to the best of my knowledge and belief following due inquiry, that the loads in the FS Demonstration made in such FS Submittal can be served by the Qualifying Resources and Net Contract QCC in such FS Demonstration.”
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.
In order to clarify that the language is referring to Qualifying Resources, Powerex suggests the following edit to ii)
“(ii) Participant [has] [does not have] There [are] [are no] certain additional outages at Qualifying Resources that are planned to occur during the [specify season] Binding Season but have not yet begun at the time of submission of the FS Submittal;”
21: Please supply any comments related to Appendix F.
No response submitted.
22: Please supply any comments related to Appendix G.
No response submitted.
General Comment
The following comment is in regards to Appendix I:
Since the senior official for the Participant may not have prepared the QCC calculations themselves, Powerex recommends revising the attestation as follows:
“I, the undersigned, who, as [title], serves as a senior official of [Participant], hereby attest that I have reviewed [Participant]’s Storage Hydro Qualifying Capacity Contribution (QCC) provided this day by [Participant] to Western Power Pool; and, to the best of my knowledge and belief following due inquiry appropriate to the reliability and resource adequacy matters addressed therein: that such QCC has been calculated in accordance with the methodology set forth in BPM 105 Qualifying Resources and such calculation meets all requirements of Tariff section 16.2.5.5;, that [Participant] has provided the Program Administrator with all information necessary to review such QCC that is stated in Tariff, section 16.2.5.5, to the extent requested by the Program Administrator, and that all statements and information included in the FS Submittal with respect to the calculation of such QCC are true, correct and complete to the best of my knowledge and belief following due inquiry appropriate to the reliability and resource adequacy matters addressed therein.”