Appendix B states “…the load for which [Participation] is seeking exclusion has been made aware of and understands the potential reliability impacts of said end-use customer’s load being excluded from the WRAP and include supporting correspondence to that effect."

The joint-ESPs believe examples must be provided of what reasonable customer education and supporting correspondence would entail for the purpose of load exclusion. 

For example, must the attestation specifically inform a customer that load excluded from WRAP may have their load curtailed in advance of declared contingency by the BAA?   If so, what documentation would be required?  Since WPP will not operate physical load shedding a (a BAA responsibility), then there are significant reliability issues for a non-BAAs to monitor and communicate any kind of preferential curtailment in advance to the customers. 

No comments.

• Appendix A:
  • The sample attestation language is missing a table to house the pertinent details that the attestation must present in order to be accepted.
  • Documents participant attaches to attestation should include specific details and values to support the load forecast modifications. 
  • Details should be submitted in a format that allows a cover page to be shared publicly, and non-public information clearly marked as confidential.
  • Program administrator should be making public notice, at least to other participants, of a non-standard modification being made, without releasing any confidential information.

• Appendix B:
  • Appendix B is missing at least one layer of Attestation, 1) the customer whose load is being excluded should be signing the Attestation along with the Senior Official of the Participating LRE.  2) BPA proposes that the Attestation should also include acknowledgement from a senior official of the BA in which the load resides that the BA is aware of the load exclusion from WRAP.
  • This attestation should include documentation demonstrating how it can be proven in the OPS program timeframe (and after the fact tests) that the load in question was excluded from the LRE’s OPS time frame submittal: how the load is specified, and how it is metered separately from the LRE’s other loads.
  • Similar to Appendix A, this submittal should include a summary for public release and have confidential materials clearly marked. The Program Administrator should presumptively accept all submitted load exclusions that meet the required documentation. However, there should also be a public notice of all load exclusion, or at a minimum to all other participants in the sub region, as this shows load within the participant’s footprint that does not have RA planning at the same levels as other loads participating in WRAP.  Notice of all load exclusions is important because load exclusions can create additional risk for other participants.

No additional comments at this time.

It may be valuable for Appendix B to reflect explicit agreement between the LRE and the customer whose specific metered load is being excluded by requiring attestations from both parties. AWEC finds it valuable to discuss whether this would be valuable from a WRAP programmatic perspective or whether these issues are best addressed through contracts between the LRE and their customers. If there is value in requiring attestations with WRAP from both the LRE and its customer, we suggest the following edits to Appendix B.

Appendix B - Load Exclusion Senior Official Attestation

Participant LRE Load Exclusion Senior Official Attestation

I, the undersigned, who as [title], serves as a senior official of [Participant], hereby request that [the amount of load served in MW that the Participant LRE is seeking to exclude] be excluded from [Participant’s] P50 Load Forecast calculation. I attest that to the best of my knowledge and belief that the customer of the load for which [Participant] is seeking exclusion has been made aware of and understands the potential reliability impacts of said customer’s load being excluded from the WRAP.

Customer Load Exclusion Senior Official Attestation

I, the undersigned, who as [title], serves as a senior official of [Customer of the specified metered load], hereby acknowledge that [Participant] is seeking to exclude [the amount of load served in MW that the Participant LRE is seeking to exclude associated with Customer’s load] from [Participant’s] P50 Load Forecast calculation at [Customer’s] request. I attest that I am aware of and understand the potential reliability impacts of [Customer’s] load being excluded from the WRAP and consent to its exclusion.

No Comment.