BAMx comments dated June 15, 2011
BAMx TPPBPM Comments on PRR #0442
The BAMx members appreciate the opportunity to provide comments to the TPP BPM changes submitted by the CAISO in PRR #0442. BAMx had submitted comments on the proposed BPM changes prior to the BPM change management process, but those submitted comments were submitted too late for the CAISO to consider. As such it is being attached here, BAMx comments datedJune 3, 2011, for the CAISO consideration and reiterated as follows. The development of generation scenarios is a critical element in the decision to designate various projects as Category 1 or Category 2 Policy Driven elements. This point was made by many Stakeholders at the CAISO April 7th meeting on the 2011/2012 Study Plan. The CAISO indicated they would provide for such a review but would need to work out the details. We fully supportthem in recognizing how important this issue is and the necessity for providing a separate, additional opportunity for Stakeholder involvement. This involvement should include an opportunity for Stakeholders to suggest scenarios to be studied and an opportunity to comment on scenarios proposed by the CAISO. The CAISO should select an appropriate time frame for this but we suggest a second quarter time frame. While Version 8.0 dated June 8, 2011, of the BPM provide that the CAISO may hold additional Stakeholder meetings in addition to those already identified at its discretion, page 12, we believe that this issue is of such significance and importance that the BPM should obligate the CAISO to explicitly provide for such additional Stakeholder opportunities. As such, the overall transmission planning process depicted in Figure 2-1 and the activity schedules listed in Tables 2-2 and 2-3 of Version 8.0 of the BPM should be modify to explicitly indicate a separate Stakeholder opportunity will be provided to discuss generation scenarios. Thank you for considering our comments.