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.
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Overview
Lead Sponsor's Description of the 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.
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Matt H. / BPA
Bonneville appreciates the opportunity to provide comment. As stated above, Bonneville is…