April 11, 2025, 3:06 p.m.
No response submitted.
April 15, 2025, 7:37 a.m.
No response submitted.
April 15, 2025, 8:05 a.m.
Electricity demand is rapidly increasing, driven by emerging loads such as electric vehicles (EVs), data centers, and widespread electrification. However, the pace of supply growth is not keeping up—slowed by interconnection queue backlogs, transmission build-out challenges, and other systemic bottlenecks. Utilities are caught in the middle, working hard to scale up power infrastructure to meet this accelerating demand.
In light of these unprecedented pressures, it is essential that utilities are given greater certainty to plan effectively for future needs. To that end, Tacoma Power proposes a modest yet important adjustment to the PRC workplan:
1. Prioritize and expedite the task force workstream focused on Forward Showing stability and monthly planning reserve margin volatility. This work should begin as soon as possible.
2. To allocate resources effectively, the load growth factor task force workstream should be postponed until 2026, allowing focus on the more urgent Forward Showing and PRM volatility efforts.
April 15, 2025, 8:40 a.m.
No response submitted.
April 15, 2025, 11:21 a.m.
No response submitted.
Seattle is curious if there will be a call out to current participants to help with moving the Concepts along in a timelier manner. The draft work plan looks to go into potential binding seasons, it would be good to expedite these Concepts and proposals before any binding season happens.
Would having additional participants contribute to this effort make it go faster?
April 15, 2025, 2:32 p.m.
PSE has comments specific to each of the CRF workplan items as follows:
2024-CRF-003, DR QCC
PSE supports the development of enhanced Effective Load Carrying Capability (ELCC) calculations for Demand Response (DR) programs. Currently, participants engage in various Demand Response, Virtual Power Plant (VPP), and similar programs, making it challenging to determine WRAP eligibility. The establishment of clearer and more comprehensive guidelines would greatly assist participants in evaluating and qualifying their potential programs.
2024-CRF-004, Day Ahead Market Optimization of the Operations Program Holdback
PSE fully endorses the optimization of Western Resource Adequacy Program (WRAP) deployments through Day-Ahead (DA) and Real-Time (RT) market re-dispatch processes.
2024-CRF-010, Capability Testing Requirements for Seasonal Compliance
We recommend that both the Tariff and Business Practice Manual (BPM) explicitly clarify the permissibility of using historical data for Operations and Capability testing requirements. It is important to recognize that thermal resources in the Pacific Northwest region typically demonstrate higher capability during winter months compared to summer due to ambient temperature variations. We strongly advocate that capability testing should be based on demonstrated data and established standards, rather than relying on isolated in-person inspections conducted at arbitrary times throughout the year. If these changes primarily involve BPM or Tariff modifications, we suggest this item could be reclassified to the "Short" time category.
2024-CRF-008, CAISO High-Priority Wheeling Through in WRAP
We support efforts to resolve ambiguities and to clearly identify acceptable transmission categories for both WRAP forward showing and operational requirements. Specifically, we advocate for explicit clarification regarding all wheel-through and wheel-out transmission and products, including the California Independent System Operator (CAISO) High-Priority Wheel-through transmission and generation Wheel-out e-tags such as the CAISO Generation-Firm Provisional (GF-P).
April 15, 2025, 2:40 p.m.
No response submitted.
April 15, 2025, 3:01 p.m.
No response submitted.
April 15, 2025, 3:56 p.m.
No response submitted.
April 15, 2025, 4:37 p.m.
No response submitted.
April 15, 2025, 5:01 p.m.
No response submitted.