03: Please supply any comments on the FS Capacity Requirement section. (3)




June 17, 2024, 3:46 p.m.
STEVE KERNS | NLSL Group
No response submitted.

June 17, 2024, 3:48 p.m.
LINDSEY SCHLEKEWAY | NVE
No response submitted.

June 18, 2024, 3:22 p.m.
GABRIELLE GLYNN | Tacoma Po…
No response submitted.

June 18, 2024, 9:14 a.m.
SANDEAP REDDY | Puget Sou…
No response submitted.

June 17, 2024, 10:53 a.m.
IAN WHITE | SE

Section 3 should address how any contingency reserve adjustments would be treated for  non-BAA LREs as these WRAP Participants do not hold contingency reserves explicitly; instead, contingency reserve requirements are maintained by the BAA in which the generation is located and with the BAA the load resides in.  

The joint-ESPs do not believe a contingency reserve adjustment to the FS capacity requirement would be warranted in this case. 


June 17, 2024, 11:12 a.m.
STEFAN CRISTEA | Portland …

No comments


June 17, 2024, 1:27 p.m.
RAJ HUNDAL | PWX
No response submitted.

June 17, 2024, 1:39 p.m.
MATT HAYES | BPA
  • The equation should be adjusted to reflect that the CR adjustment could be in either direction.
  • Remove the ability to use the Demand Response Modifier

June 17, 2024, 3:51 p.m.
BENJAMIN FAULKINBERRY | PacifiCor…
No response submitted.

June 17, 2024, 4:32 p.m.
JERRET FISCHER | SRP

The paragraph implies that the monthly Demand Response Load Modifier is known as the “FS Capacity Requirement Unadjusted”.  SRP understands that the intent is to define the net result after adjustment by the monthly Demand Response Load Modifier as the “FS Capacity Requirement Unadjusted”, SRP recommends more clearly attaching “FS Capacity Requirement Unadjusted” to the net result.

SRP appreciates the Equation 1 detail, which was useful to understand the intent of this section.


June 17, 2024, 4:39 p.m.
TYLER MOORE | Arizona P…

APS would support the removal of the Demand Response Load Modifier in the equation for FS Capacity Requirement Unadjusted as discussed in response to prompt and Section #2.


June 17, 2024, 6:13 p.m.
SOMMER MOSER | Davison V…
No response submitted.