No Comment.

The definition for customer contracted load does not contemplate a situation where an end user of energy procures energy and capacity both from the host BAA (and WRAP Participant) and another supplier such as a competitive energy service provider.  In this case, the definition presumes that a WRAP Participant would not plan for the load consistent with the Forward Showing timeline.  The joint-ESPs believe this is an oversimplification and does not reflect nuances of contracting for customer loads where instantaneous demand is served by the load’s host BAA while defined products are provided by a competitive energy service provider. 

No comments

• Contingency Reserve Adjustment: Suggest revising the Contingency Reserve Adjustment to the following: Contingency Reserve Adjustment: An adjustment to the FS Capacity Requirement to account for changes in Contingency Reserve requirements resulting from a Participant’s contractual purchases and sales, which include the Contingency Reserve as a specific part of the contract. The Contingency Reserves have two components, and the Contingency Reserve Adjustment could impact either of both components: Generation and Load. This adjustment can be positive or negative in direction based on contract direction: purchase or sale.

• Customer Contracted Load: Suggest revising the Customer Contracted Load definition to the following: A metered customer load (specifically metered) located within the Participant LRE’s Service Territory where the customer as the ultimate consumer of electricity has exercised the option to be fully responsible for all  purchase capacity and energy on its own behalf and, because of this, the Participant is not the exclusive supplier of capacity on a forward basis and therefore does not plan for the load on a timeline consistent with the Forward Showing.
  • Specifically, the Customer Contracted Load definition should use the term Service Territory rather than Balancing Authority Area

• Demand Response Load Modifier:  The purpose and/or use of the load modifier option is unclear, and we suggest it be removed. Since the load modifier option clearly states “will require the same registration, Capability Testing, and Operational Testing requirements as required of Demand Response used as a Qualifying Resource” – why are we giving an option of load modifier if a participant already has to do all steps required to get a QCC (option 2) and is required to submit them in some fashion to prove the load modifier is accurate.  We are not clear on how the program would call on a ‘Load Modifier’ and how this just doesn’t result in a participant that is using the modifier always having a load forecast that is greater then expected in the OPS program.

• Forward Showing (FS) Capacity Requirement Unadjusted: Suggest revising this definition to the following: The FS Capacity Requirement Unadjusted takes into account Demand Response used to reduce monthly P50 Peak Load Forecast embedded in the historic load data set and the monthly FSPRM. The FS Capacity Requirement Unadjusted does not take into account the Contingency Reserve Adjustment. 

• Super Peak Months: The name “Super Peak Months” needs to be changed. Super Peak is a regularly used term that does not represent Dec, Jan, Feb. This will cause confusion.

Concerning ‘Customer Contracted Load’: WRAP Participants participate at the LRE level, not necessarily the BAA level.

Concerning the term ‘Super Peak’: ‘Super Peak’ is already a common industry term for a type of energy product. Using a different term is recommended in this BPM, such as ‘Core Winter Months’ or ‘Winter Peak Months’.

SRP appreciates the definitions provided in BPM 103. However, SRP requests enhanced and clearer definitions for ‘Contingency Reserve Adjustment – Load’ and ‘Super Peak Months.' For the ‘Contingency Reserve Adjustment – Load’, it would be helpful to include information on criteria related to how load adjustments are calculated and applied. For ‘Super Peak Months,’ clarification would be helpful on the rationale and criteria for the selection of these months, and how they differ from other months.

The definition for Contingency Reserve Adjustment – Load indicates that it is an adjustment and the definition for Contingence Reserve Adjustment – Generation speaks to a difference between two values, where the definition for load just says it accounts for Contingency Reserve purchases and sales but not against the level assumed in the LOLE study, APS thinks it is also an adjustment from the LOLE study and the definition should represent that.

Customer Contracted Load having the “Participants BAA” in the definition is confusing since the LRE is the compliance responsible entity in WRAP and does not represent the loads of any single BAA. A better way to define this is probably to say a load that the entity is the load responsible entity for but does not do the resource adequacy planning for (regardless of reason or BAA of the load).

AWEC appreciates the opportunity to provide comments on BPM 103. Related to the definitions section, AWEC is concerned that the definition of “customer contracted load” is vague and ambiguous as drafted. It is AWEC’s understanding that the intent of the load exclusion provision is to place the risk of a capacity shortage on the excluded load, as opposed to WRAP. However, the language as drafted could be read to require, as a condition of load exclusion, that consumer loads must actually purchase capacity on their own behalf as a condition of load exclusion from WRAP. This would be an additional requirement, which is beyond our understanding of the intent of the provision and raises additional concerns given the voluntary nature of the WRAP, and would effectively nullify the purpose of load exclusion since the excluded load would still need to demonstrate its capacity position. Consumers sophisticated enough to pursue and consent to load exclusion should be permitted to take on the risks of such a decision.

If AWEC’s understanding of the intent of this provision is incorrect, we would like to understand the rationale for requiring excluded load to demonstrate its capacity position, including relevant tariff provisions.

In order to clarify the definition, AWEC suggests amending the definition of “Customer Contracted Load” to read as follows:

Customer Contracted Load: A metered retail load located within the LRE’s Service Territory where the customer of LRE: (a) does not purchase energy from LRE to serve the metered retail load; and (b) has exercised the option to forego the LRE planning for the metered retail load on a forward basis. For purposes of this definition, a customer and retail-end user whose load is subject to exclusion may be the same.