01 Please supply any comments related to the Introduction, Definitions, or Background sections.
No response submitted.
02 Please supply any comments related to the Resource Registration – Resource Eligibility and Timelines section.
- Resource Registration – Page 3 – Resource Eligibility and Timelines: The work ‘All’ should be removed from the first sentence! Participants should have the ability to register resources as they determine, if they have a resource that they do not wish to register or make available that is (should be) their own discretion, stating ‘ALL’ takes that out of the participants hands. Rules defined in this BPM already describe late registration and require that it be newly acquired and to show that, as a result a resource not submitted couldn’t be added for Forward Showing because the party is short, this is participant decision.
- In Table 1 – page 5 – and Table 3 – page 7 - 'Ownership or Contracted Percentage for Participant' - Resource registration is part of advance assessment – Participant share isn't needed until Forward Showing, why is this part of resource registration.
03 Please supply any comments related to the Resource Registration – Late Registration of Resources section.
- Note that utilizing a class average for new Storage Hydro resources is problematic and would be difficult to apply in practice. Different hydrological conditions, reservoir limitations and size, and non-power constraints will vary by project. Propose somethgin on the line of participant can propose a methodology consistent with the Storage Hydro methodology for calculating the QCC of the resource. Modelling approach will be reviewed and approved by the Program Administrator/Program Operator.
04 Please supply any comments related to the Resource Registration – Qualifying Resource Aggregation section.
No response submitted.
05 Please supply any comments related to the Resource Registration – Generator Testing section.
No response submitted.
06 Please supply any comments related to the Resource Registration – Operational Testing section.
- Storage Hydro Resources - Need to clarify that operational test can be conduct at plant level (aggregate of multiple units in single facility), however outages and derates need to be included at the individual unit level.
- Run of River Hydro – should be ‘project’ or ‘plant’ and not ‘unit’
07 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.
No response submitted.
08 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.
No response submitted.
09 Please supply any comments related to the Resource Registration – Provision of Test Reports in the FS Submittal section.
No response submitted.
10 Please supply any comments related to the Resource Registration – Testing for Late Registered Resources section.
No response submitted.
11 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Background section.
No response submitted.
12 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Qualified Resources Included in FS Submittal That Have No QCC Previously Calculated section.
No response submitted.
13 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Thermal Resources section.
- Table 4 – page 15 – FOH and EFDH definitions are missing the sub script of CCH used in formulas.
14 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Variable Energy Resources section.
No response submitted.
15 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Energy Storage section.
- Allocation of ELCC for ESRs – page 26 – second half of paragraph is referencing both ESRs and VERs, does this need to be in its own section clearly calling out this methodology to assure over-accreditation doesn’t happen?
16 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hybrid Facilities section.
No response submitted.
17 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Demand Response section.
No response submitted.
18 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hydro Resources section.
No response submitted.
19 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Other Resources section.
No response submitted.
20 Please supply any comments related to Appendix A.
No response submitted.
General Comment
The usage of the terms “unit”, “plant”, “project” and “resource” throughout the BPM is confusing, they should be defined and used appropriately. While specific aspects of the Forward Showing, such as outages, use unit level data, a Resource has an accredited QCC at the plant/project level. The use of ‘unit’ in plant/project level descriptions is confusing.