NLSL Group Comments on WRAP’s Draft BPM103 v0.2

The NLSL Group[1] includes discrete large loads that are expected to result in 1.5-4.5 GWs of BPA’s Total Retail Load[2] by 2028.  At this time, the NLSL Group is exploring paths for these loads to be included as part of BPA’s Load Responsible Obligation (LRE) obligation as well as a potential path for having large loads act as their own LRE.  In order for members of the NLSL Group and their large load customers to make a well-informed decision on WRAP participation, Western Power Pool (WPP) procedural and business practice manuals (BPM) will be required.  The NLSL Group has reviewed BPM 103 v0.2, has discussed the load exclusion portion with BPA, and offers these comments.

Customer Contracted Loads (CCL): 

BPM 103 v0.2 provides the following definition of a CCL:

A metered customer load located within the Participant’s Balancing Authority Area where the customer as the ultimate consumer of electricity has exercised the option to purchase capacity on its own behalf and, because of this, the Participant is not the exclusive supplier of capacity on a forward basis and does not plan for the load on a timeline consistent with the Forward Showing.

As it pertains BPM 103 - Section 7 Excluding Load – Participants with CCLs in their BAA may elect to exclude loads from WRAP.  We are seeking clarification for the description of CCLs - is it the intention of the WPP to require the ultimate consumer of electricity to demonstrate that they have “exercised the option to purchase capacity” as a condition of Exclusion?  As written today, it can be interpreted as a requirement for CCLs to demonstrate the purchase of capacity as a condition of Exclusion.

Operational Program

BPM 103 v0.2 provides information on load exclusion during the Forward Showing program. Will there be business practices developed that describe how excluded loads will be treated during the operational program?  The attestation in Appendix B refers to reliability impacts of load exclusion – will these reliability impacts be discussed in other business practices?

Load Exclusion Decision-Making

The NLSL Group would like additional information on the decision-making process for load exclusion requests.  We request more specific information regarding load exclusion determinations including what criteria will be used and how any appeal process will be conducted.

Voluntary Nature of WRAP

Due to the fact that WRAP participation is a voluntary decision, the NLSL Group would like the WPP to affirm that no WRAP Participant can require a CCL to participate in the WRAP program or unilaterally assume LRE responsibilities for purposes of WRAP.

Conclusion

The NLSL Group believes that a successful WRAP program is one of the highest priorities for the region and appreciates the work that has been accomplished to date.  As mentioned earlier, the NLSL Group and their large load customers desire to make a well-informed decision on WRAP participation and look forward to additional WPP procedural and business practice development to assist with these decisions.

Submitted by Steve Kerns (Sandpiper Solutions, LLC), on behalf of the NLSL Group.

sandpiper@kernsfunk.net

[1] The NLSL Group is comprised of BPA preference customers who serve or expect to serve retail members and customers that the Northwest Power Act categorizes as “New Large Single Loads” (NLSLs).  Member utilities include: Umatilla Electric Cooperative, Northern Wasco County PUD, Grant PUD, PNGC Power, Clatskanie PUD, Harney Electric Coop, Klickitat PUD, and Eugene Water and Electric Board.

[2] Slide 37, https://www.bpa.gov/-/media/Aep/power/resource-program/rp-2023-11-28-public-workshop.pdf

BPM 103 does not consider where an LRE serves a specific amount of load to a customer whose entire load may be split between suppliers that may or may not both be WRAP LREs.  For example, how would WRAP accommodate a hypothetical 50 aMW load which has elected to procure 35 MW of energy and WRAP capacity from supplier A and 15 MW from supplier B?  In this case, supplier A is a WRAP participant and is LRE for 35MW (plus the PRM); whereas, supplier B could be LRE for 15 MW if they were a WRAP participant but also may not be a WRAP participant in another version of this question.  The joint-ESPs maintain these nuances should either be defined in BPM 103 or a separate BPM for non-BAA LRE nuances should be considered. 

If there is a required RA standard imposed by a particular jurisdiction which mirrors the WRAP program, e.g. the Oregon PUC RA program pursuant to UM2143, will load be excluded from WRAP should the load elect to meet the State RA program?  If so, would the same load exclusion process apply?   

No comments.

• WRAP is not a BA level program, replace “BAA” with “Service Territory”

• Is this section trying to say that a Participant with loads outside its Primary BAA could exclude those loads from WRAP? As an example, BPA could exclude any and all load that is outside of BPAT? Fundamentally, that would be a BA based resource adequacy approach that each BA is responsible for the RA of all loads inside the BA (and nothing outside).  WRAP was developed as a LRE program. This seems to fundamentally break the Resources Adequacy model that was chosen for WRAP. Section 8 specifically goes into multiple sub regions. Sub regions by nature would encompass disparate BAs.

If load is excluded from the FS, how is that load treated during the Operations Program, if the details are covered in another BPM can we note such BPM in this section? If the load is excluded and there is a shortfall does that mean that that load is subject to curtailment? 

AWEC does not believe that WPP should institute a substantive review or approval process once loads have elected to be excluded from WRAP in accordance with the attestation in Appendix B. However, the Excluding Load section lacks detail and clarity on the process that will occur at WPP, if any, related to whether there will be an approval or acknowledgment process from WPP that load has been excluded. If WPP has the discretion to preclude load from being excluded that is otherwise supported by the Appendix B attestations (as proposed to be amended by AWEC), what is that process? When and how will determinations be made? What criteria will WPP consider in making such a determination? Will there be any type of conferral or appeals process prior to or following a determination from WPP that load may or may not be excluded?  Additional language clarifying the process, or lack thereof, is needed.

Would we need the customer to attest that they will be foregoing any potential WRAP related capacity benefit if their load is excluded via Customer Contracted Loads. Do we need to inform customers that they have an option?