COMMENT FOR BPM 106 - Qualifying Contracts

Submitted April 1, 2024, 2:38 p.m.



01: Please supply any comments related to the Introduction, Definitions, or Background sections.

No response submitted.

02: Please supply any comments related to the Contracts Eligible for QCC value section (3).

No response submitted.

03: Please supply any comments related to the Contracts Eligible for QCC value - Resource-Specific Capacity Agreements section (3.1).

No response submitted.

04: Please supply any comments related to the Contracts Eligible for QCC value - System Sale section (3.2).

 “Resources associated with qualified System Sales from sellers that are not Participants do not have to be registered.”

Does this mean that these resources are not to be submitted during the advance registration? Don't see a reason for making such exclusions.

05: Please supply any comments related to the Joint Contract Accreditation Forms section (4).

No response submitted.

06: Please supply any comments related to the Calculating Net Contract QCC section (5).

No response submitted.

07: Please supply any comments related to the Resource Adequacy Transfers (RA Transfers) section (6).

No response submitted.

08: Please supply any comments related to Appendix A.

No response submitted.

09: Please supply any comments related to Appendix B.

No response submitted.

10: Please supply any comments related to Appendix C.

No response submitted.

11: Please supply any comments related to Appendix D.

No response submitted.

General Comment

There have been discussions in the past for JCAF requirements relating to PURPA and other small contracts. It would be helpful to clearly list in a table format all contract types that need and don't need a JCAF based on various attributes.

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