No response submitted.
June 17, 2024, 10:53 a.m.
June 17, 2024, 11:12 a.m.
Comment 1:
Regarding the paragraph: “…, the Participant will demonstrate that the alternative growth rate results in a peak load forecast 5% higher or lower than the peak load forecast calculated using the appropriate established growth rate discussed in Section 5.1.”
What is the basis for the 5% threshold? The approved FERC Tariff does not provide for an alternative peak load forecast limit.
PGE has concerns regarding the materiality of the 5% threshold because, based on the magnitude of an entity’s load in future years, the 5% can be very significant. PGE recommends removal of the 5% threshold and instead, the PO/PA require that participants submit detailed documentation to demonstrate the reasoning for their alternative load forecast. The PO/PA can reserve the right to deny if the Participant’s documentation does not support their alternative load estimate or if it is not materially different from the PO/PA provided estimate.
Comment 2:
Suggest providing a weblink for more direct access to the alternative growth rate request form.
No response submitted.
No response submitted.
NV Energy appreciates the opportunity to comment on Business Practice Manual (“BPM”) 103 and offers the following comments for the Western Power Pool’s (“WPP”) consideration. The BPM references a form for the alternative load growth method that is located on the WPP website. NV Energy was not able to locate this form and recommends that the WPP either attach the alternative load growth rate form to the BPM as an appendix or include the form with this BPM for review along with the BPM. NV Energy would like to review the form and the data that would be necessary in order to utilize this method. If it is not possible for stakeholders to review the form at this time, then WPP should include all required data needed for this alternative method in this BPM so that stakeholders have the ability to comment.
NV Energy does not support the inclusion of a requirement in order to use the alternative method. The alternative method should be allowed regardless of the difference between the peak load determined from the program load growth rate and would be inequitably applied to different participants based on the size of their loads as currently proposed. Therefore, NV Energy recommends that the last sentence of Section 5.2 be removed and that no requirement be applied to the alternative growth rate.
The 5% threshold for an alternative load forecast should be removed. If a Participant can acceptably demonstrate an alternative load forecast to the Program Operator, it should be able to be utilized. The 5% threshold can impose significant financial consequences to Participants, and potentially expose the WRAP to increased RA risk.
For a Participant with a large load footprint, the forward procurement costs associated with just 1% of P50 can result in several million dollars of additional net power costs to that Participant’s customers.
For example, if a Participant’s internal forecast results in a P50 of 9,500 for July, while WRAP forecasts a P50 of 9,785MW for July, which has a PRM of 15%. 9,500 is not more than 5% different than 9,785, so WRAP will hold the Participant to the 9,785 P50 value, resulting in the Participant needing to provide (or procure) an additional 328MW than necessary. 285MW additional load + 15% PRM = 328MW additional capacity requirement for July.
Conversely, a Participant whose internal P50 load forecast exceeds the value provided by the PO by less than 5% can potentially lean on the program and be within bounds of this BPM.
While PacifiCorp believes WRAP Participants to be acting in good faith, a Participant whose internal load forecast exceeds the monthly P50 provided by the PO, regardless of by how much, is incentivized to not report that information.
As an additional note, please include the form referenced in this section within the BPM itself for review. The form itself may impose requirements not subject to a review process.
SRP encourages the WPP to review the requirement that the alternative growth rate must produce a load forecast difference of at least 5% from the established growth rate. A difference of at least 5% is a high bar, as a 5% difference for a 10,000MW peak translates to a significant 500MW. SRP suggests consideration of a lower relevance threshold, e.g. at least a 2% difference in future load from the established growth rate. This lower threshold could potentially make it more feasible for participants to propose and justify alternative growth rates.
As a related concern, there is seemingly no clear incentive for participants to voluntarily report a higher growth rate under the current high threshold."
APS feels that it would be best to specify up front in the section that proposed changes should only be submitted if load differs by at least plus or minus 5%. APS also would highlight there is a natural incentive for entities that have lower than 1.1% growth rates to pursue an alternative growth rate. While entities with above 1.1% are disincentivized because of the lower resource requirement calculated when using 1.1%. How does the program maintain RA if entities with lower growth rates “drop out” from the higher resource requirement? Alternatively, if the growth rate of other participants is revised whenever a participant switches to an alternative rate, will entities have enough time to procure the necessary resources to avoid penalties? This rate needs to be fairly steady, as resource procurements occur over multi-year periods.
No response submitted.
No response submitted.