| Comment: |
I appreciate BPA's diligence in trying to follow the TRM especially as it relates to section 5.3.5.2 Calculating CDQs. I have two concerns with the process however. The first concern is the language in the TRM section 5.3.5.2 which states "That is, BPA will remove eccess CDQ headroom only, without establishing the CDQ so as to expose the Customer to a Demand Charge in such month." I interpret that to mean that there won't be a demand charge but head room will be removed. It seems that sentence could be interpreted to mean that the CDQ would be adjusted to expose the Customer to a Demand Charge. This needs to be clarified. My next concern is that through the filtering process some utilities might have had headroom removed and be worse off than utilities that didn't have to go through the adjustment process. Said another way we have less headroom than a utility that was not adjusted. My final comment is that if BPA is going to go forward with the filtering process I favor the annual filter. Thank you for the opportunity to comment. |
