Request Summary
Additional DR Category for Loads Utilized as CR
Co-sponsors
Description Of Issue
The WRAP Design Document contemplates a Demand Response (DR) category for loads which are utilized for Contingency Reserves (CR) only (Page 73, paragraph one). Subsequently, this category was not incorporated into BPM 105. This additional DR category would provide an appropriate place for Participants to account for DR programs designed to be primarily operated as CR.
Proposed Solution
Amend BPM 103 and BPM 105 to add and describe the new category. Possibly additional BPM references.
Specific Document And Language
BPM 103 Section 2
BPM 105 3.4.2.3, 3.4.3.6
Possibly more may apply.
Suggested Language Update
BPM 103
“A Participant has three options when choosing how to use Demand Response to affect its Monthly FS Capacity Requirements in its FS Submittal (see BPM 108 FS Submittal Procedure).
- (New Bullet) A Participant may include a Demand Response program for the purpose of satisfying the Participant’s Contingency Reserve requirement in its FS Submittal. The extent to which a Participant may use this category is limited by the monthly MW total of its CR requirement, as well as by parameters as outlined in BPM 105.
BPM 105
3.4.2.3
(New Paragraph #2) Demand Response programs can be categorized as contributors toward the CR requirement of a Participant’s FS Submittal only. Demand Response programs in this category are not considered Qualifying Resources and thus not subject to testing requirements beyond those required by NERC. A Participant using this category may be requested to provide evidence to the satisfaction of the PO that the load relief claimed in the FS Submittal is appropriate, and the attributes of the program or programs satisfy operational requirements to provide Contingency Reserves, such as response time and number of available calls/hours.
3.4.3.6
For DR programs claimed as a Qualifying Resource, an Operational Test will be conducted yearly during the Participant’s peak Binding Season and at a minimum of 50% of the DR program’s claimed load reduction capability (to avoid unnecessary disruption to the Participant’s customers). The duration of an Operational Test shall be for a minimum of one hour.
Benefits
Without a sacrifice of program reliability, flexibility of the WRAP will be increased to accommodate valid DR programs which do not fit neatly into either of the two current DR categories.
Data Or Information
NERC Standard BAL-002-WECC-3 includes DR as a valid resource to provide Contingency Reserves. “Non-spinning” resources not only satisfy this NERC requirement, but also help utilities meet state-imposed environmental targets, as less idle spinning generation is required to satisfy reliability standards. Utilities have designed programs or established contracts with this dual benefit in mind. Most utilities employing these programs are subject to NERC standards as well as rules needed to maintain good standing in any applicable Reserve Sharing Group.