Western Resource Adequacy Program / Change Requests

Change Request 2024-CRF-015

Awaiting workplan review Enhancement

Request Summary

Clarification Planned Outages Tariff Language/BPM 108

Co-sponsors

Tyler Moore

Arizona Public Service

602-250-2167

tyler.moore@aps.com

Description Of Issue

Fundamentally, we feel there are issues with the tariff language on Planned Outages.  The tariff has a very narrowed scope defining specific Planned Outages, and what may qualify for an exemption.  Exemptions appear defined as:  out from FS to Binding Season, less than a static value of 500MW per participant, and limited to a single resource(s).  Second, there appears to be contradictory, or at minimum, confusing language between the Tariff and the BPM defining Planned Outages in the Forward Showing concerning outage exemptions.  Lastly, we have concerns around the compressed time frames, in between non-Binding Seasons, in which Participants could inadvertently create resource adequacy issues planning all regular maintenance outages.

 

Understanding the Focus of the Tariff:

16.2.8                    “Participants shall include in their Forward Showing Submittal for a Binding Season information on all Qualifying Resources that are currently out of service with a scheduled return date that falls during the Binding Season.  Capacity associated with such resources must be deducted from Participants’ Portfolio QCC as specified in the Business Practice Manuals to ensure no credit is granted for such resources during the planned outage.  The aggregate of any additional outages that are planned to occur during the Binding Season but have not yet begun at the time of submission must be within the Participant’s remaining surplus (or replaced with other supply).  Participants may provide information on all Qualifying Resources that are planned to be out of service but if such data cannot be supplied with reasonable specificity, a Participant may provide Senior Official Attestation at the time of the submission of its FS Submittal this is expects the sum of planned outages to be equal to or less than the surplus stated in its FS Submittal throughout the Binding Season.”

16.2.8.1                “If a Qualifying Resource is planned to return to service within the first five days of a Binding Season, WPP may approve a qualified acceptance of the FS Submittal, provided the deficiency is less than 500 MW.”

16.2.8.2                “A planned outage shall not justify a waiver of or exception to a Participant’s holdback or energy delivery obligations under Part III or this Tariff.  Participants will be expected to procure the necessary capacity or energy to meet the Operations Program requirements, regardless of planned outage schedules or FS Submittal acceptance.”

 

The Tariff is very specific, and it appears the main concern is Planned Outages out at the time of FS Submittal which will remain out once Binding Season begins.  Why is the tariff so narrowly focused?

  • There is no mention of a planned outage beginning:
    • After the close of the FS Submittal period
    • During the FS Cure period
    • After the close of the FS Cure Period
  • All these other options, are then assumed, to be included in the language, “The aggregate of any additional outages that are planned to occur during the Binding Season but have not yet begun at the time of submission must be within the Participant’s remaining surplus (or replaced with other supply).”
  • If the Tariff is specifying outages, out at the time of the FS Submittal, and still out once the Binding Season begins, then it is focused on planned outages that are 7+ months in duration.  This equates to outages 215+ days in length.  We would like to understand this thought process.

 

Exemptions

16.2.8.1 is very specific as what may qualify for an acceptance.

  • Assumption:  only applies to outages defined in 16.2.8, out from FS to Binding Season.  Thus 7+months or 215+ days.
    • Also assumed it is limited per resource, out for 7+ months or 215+ days.
  • Must return within the first 5 days of the Binding Season.
    • Therefore, Summer June 1-5 only?
    • And Winter November 1-5 only?
  • Must not be above a static 500MW

 

 

Potential Contradiction Tariff/BPM and Need for Clarification

The Tariff does mention in 16.2.8.1 WPP may approve a qualified acceptance for the FS Submittal should the planned outage return to service within the first five days of the Binding Season.

However, per BPM 108:

3.1.5.1.                 “Any Qualifying Resource that is out of service at the time of the FS Deadline and is planned to remain out of service for the first five or more days of a month in the Binding Season cannot have such Qualifying Resource’s QCC counted toward meeting the Participant’s FS Capacity Requirement for that month. To ensure QCC from resources is not utilized to meet a monthly FS Capacity Requirement during the planned outage, the Capacity associated with such resources shall be deducted by identifying the planned outages in the FS Demonstration.”

  • The Tariff language states WPP may approve a qualified acceptance while the BPM specifies it cannot count.
  • It’s possible the intent was to quantify an outage lasting longer than the first five days of the binding season cannot count; however, the inclusion of “…is planned to remain out of service for the first five or more days of a month…” makes the intent confusing.  Specifically, the inclusion of ‘or’.

 

Logistical Issues with Planed Outages

  • Participants are limited to a specific number of calendar days for maintenance, should they wish to ensure they get full credit for all available QCC values in FS Submittals.
  • Between the end of Winter Binding Season and the beginning of the Summer Binding Season
    • March 16 – May 31st
    • 77 calendar days
  • Between the end of Summer Binding Season and the beginning of the Winter Binding Season
    • September 16 – October 31st
    • 46 calendar day
  • Total of 123 calendar days for maintenance, should a participant wish to avoid risking losing QCC availability.
    • During these 123 calendar days, 21 WRAP entities (excluding Shell) will be trying to schedule all maintenance
      • This potentially could limit the availability of contractor labor, should all entities be vying for the same 123 calendar days.

This potentially could inadvertently create a resource adequacy issue, outside of the binding season, as all participants could be taking a great deal of capacity out of service at the same time.

 

 

 

Proposed Solution

More clearly defined language to the WRAP Tariff, specifically articles 16.2.8 and 16.2.8.1.  Also, change to the language for BPM 108, specifically 3.1.5.1.  Broaden the definition to planned outages, specify what qualifies for an exception. Provide more flexibilities for WRAP entities to better manage planned outages.  Allow for some flexibility for participants to take into consideration of their portfolio size.  Not limit to single outages, out for long durations, and limited to a static MW value.

Specific Document And Language

16.2.8                    “Participants shall include in their Forward Showing Submittal for a Binding Season information on all Qualifying Resources that are currently out of service with a scheduled return date that falls during the Binding Season.  Capacity associated with such resources must be deducted from Participants’ Portfolio QCC as specified in the Business Practice Manuals to ensure no credit is granted for such resources during the planned outage.  The aggregate of any additional outages that are planned to occur during the Binding Season but have not yet begun at the time of submission must be within the Participant’s remaining surplus (or replaced with other supply).  Participants may provide information on all Qualifying Resources that are planned to be out of service but if such data cannot be supplied with reasonable specificity, a Participant may provide Senior Official Attestation at the time of the submission of its FS Submittal this is expects the sum of planned outages to be equal to or less than the surplus stated in its FS Submittal throughout the Binding Season.”

16.2.8.1                “If a Qualifying Resource is planned to return to service within the first five days of a Binding Season, WPP may approve a qualified acceptance of the FS Submittal, provided the deficiency is less than 500 MW.”

 

3.1.5.1.                 “Any Qualifying Resource that is out of service at the time of the FS Deadline and is planned to remain out of service for the first five or more days of a month in the Binding Season cannot have such Qualifying Resource’s QCC counted toward meeting the Participant’s FS Capacity Requirement for that month.

Suggested Language Update

Potential Recommendations to Language Changes to the Tariff and/or BPM

  • Adjust the start of the Winter Season from November 1st to December 1st (or a mid-November date)
    • PNM has an “unwritten rule”, per the direction of our generation personnel, that it’s acceptable to schedule planned maintenance up until Thanksgiving week, specifically for contract labor.
    • In the spring the “unwritten rule” is scheduling up until Memorial Day week.
    • Consideration for what may be “Winter” or “Summer” binding seasons for SWEDE may differ for MIDC, allow for some flexibility.
  • Remove the language that specifies “…all Qualifying Resources that are currently out of service (at FS) with a scheduled return date that falls during the Binding Season.”
    • Eliminate the specification of outages that are 215+ days in length.
    • Eliminate that it’s limited to a single unit (or units).
  • Change Tariff and BPM language that allows for entities to submit a Qualified Acceptance for outages, falling within the Binding Season, provided they are: (just examples, this could be added to)
    • Within the first or last XX days (number TBD) of the Binding Season.
      • Or eliminate this definition all together.
    • The outage is not planned for a duration longer than any 5 days total (or number TBD) within the Binding Season.
    • The outage(s) is(are) a portfolio wide threshold.
      • Eliminate the static value of 500MW for all participants regardless of size
      • Perhaps make the value a percentage of a participant’s P50 Load + PRM (TBD)

Benefits

Clarifying the intent of the Tariff and BPM language would be beneficial.  Allowing entities to better understand which outages may qualify for an acceptance. 

Also, these recommendations would provide some flexibility to entities, specifically potentially expanding the overall maintenance window by 60 calendar days. 

Lastly, it would also ensure all WECC entities can comfortably schedule required maintenance and not be competing with one another for limited resources, or inadvertently creating resource adequacy issues outside of Binding Seasons.

Data Or Information