Request Summary
Change Definition of a Load Responsible Entity (LRE)
Co-sponsors
Description Of Issue
A fatal flaw in WRAP is putting an LSE in the shoes of a balancing authority. This may work in an abundant resource and transmission availability situation but not for a program like WRAP or any stressed resource or transmission condition.
The Load responsibility is ultimately and always the BA - if an LSE either acquires and cancels load contracts - the LSE does not build or retire generation let alone transmission. As you know, for APS - APS is the BA, as they should be.
Whether or not an LSE is commercially successful in acquiring load, the BA has the responsibility to maintain the transmission and distribution systems to meet all of the load within their BA.
Proposed Solution
Make an addition to the definition of an LRE to specifically NOT include LSE's.
Specific Document And Language
WRAP Tariff Definitions (Section 1)
Add a sentence at the end to specifically define who the LRE is for an LSE.
Suggested Language Update
Add this clarification at the end of:
- Definitions : Load Responsible Entity:
For an LSE, the Load Responsible Entity (“LRE”): is the BA , within the WRAP footprint, where the load is electrically connected to the BA system
Benefits
System Operations:
During a Resource Adequacy event, it is imperative that the syst3em operators have direct contact with the BA's - not through intermediaries (LSE's)
System Planning:
The commercial success of an LSE is not a load forecast to be used in system planning for resources nor transmission.
Data Or Information
Absent this change, or a deferral or significant change of the FT penalties - WRAP is not a viable program for the retail sector.