Request Summary
Definition of Generation and Transmission Facilities in BPM 209
Co-sponsors
Description Of Issue
BPM 209 references “generation facility” and “transmission facility” regarding Energy Deployment Waivers but these terms are not explicitly defined. This creates ambiguity when determining eligibility for waiver and evaluating compliance obligations. While the WRAP Tariff defines “Qualifying Resource,” the lack of an explicit definition for “generation facility” creates uncertainty as to whether it applies to only standalone plants or if it includes hybrid resources, co-located assets, or other resources submitted in a participant’s Forward Showing. Similarly, for transmission facilities, there is ambiguity when curtailments occur outside of a participant’s BA on transmission systems that are important for meeting compliance requirements of WRAP.
Proposed Solution
Add clear definitions to BPM 209 for “generation facility” and “transmission facility.”
Specific Document And Language
- BPM 209
- Section 1.4 - Definitions
Suggested Language Update
Generation Facility – any unit or resource, provided it meets the applicable WRAP requirements, that is relied upon to provide energy for meeting a participant’s compliance obligations under WRAP.
Transmission Facility – any transmission asset or service, provided it meets the applicable WRAP requirements, that is relied upon to deliver energy for meeting a participant’s compliance obligations under WRAP.
Benefits
Provides clarity and consistency in wavier evaluations, reducing the potential for misinterpretation. Will ensure that there is a reasonable path for unexpected curtailment of transmission outside of the Participant's BA that was part of the Participant's plan to meet obligations.
Data Or Information
N/A