Shell Energy North America (US), L.P. ("Shell Energy") appreciates the opportunity to submit comments on the Section 105 -- Qualifying Resources BPM.  

City Light recommends that a table should be added to each business practice.

City Light recommends that any references to other documents contain a link or reference to where those documents can be found.

DISREGARD - OUTDATED COMMENTS

Powerex would like to highlight the usage of the terms “unit”, “plant”, and “resource” throughout the BPM. While some aspects of the Forward Showing do involve unit level data, a Resource under WRAP is accredited QCC at the plant level. The choice of wording should be clear when a requirement is for a plant versus a unit.

Powerex also cautions on using defined terms in the BPM with capitalization, unless that term is included in the Definitions section of the BPM, or in the Tarriff. An example would be the term "Historical Outage Evaluation Equivalent" being used in Appendix A, but no other mention of what that defined term is. If no definition is necessary, then Powerex suggests removing the capitalization from the term.

Powerex also believes the BPM would benefit from having section headers and numbering, along with a Table of Contents. This would help participants navigate the BPM and be able to find relevant sections as needed.

While we found Business Practice Manual 105 to be an insightful document, we struggled somewhat with it as a business practice.  Our expectation of WRAP business practices is that they provide a set of instructions for WPP participants to perform so that they may achieve certain requirements of the WRAP tariff.  This document seems to read more broadly, including processes occurring at the WPP or the Program Operator (PO).  While we appreciate the WPP and PO being transparent about their activities, it sometimes causes confusion as to whether a particular activity is the responsibility of the WRAP participant, WPP, or PO.  Other information included in the document including examples and background is likewise informative, but these sections do not directly help us meet our commitments under the tariff.  As a result, we have found ourselves doing more searching and interpreting than we would normally expect in a business practice document.  As WPP progresses with Business Practice development, we would encourage it do modify its approach along the following:

1. Publish an outline or title summary of all anticipated business practices

2. Publish a business practice that contains all acronyms and definitions

3. Publish any form or workbook identified in a draft business practice at the time of the draft business practice posting

4. In initial business practice versions, limit discussion of background, purpose, or examples and instead focus on developing concise documents that identify actions required of program participants.

The usage of the terms “unit”, “plant”, “project” and “resource” throughout the BPM is confusing, they should be defined and used appropriately. While specific aspects of the Forward Showing, such as outages, use unit level data, a Resource has an accredited QCC at the plant/project level.  The use of ‘unit’ in plant/project level descriptions is confusing.

How are forced outages treated? Or is this addressed in another BPM and, if so, which one?

Maintenance outages outages is not included in this document- should it be? If so, how should planned maintenance be considered for outage of 3 days or less (full exclusion or partial capacity reduction?) Also how to consider cascading unit outages at multi unity facilities, where no more than 1 unit is out at a time? 

APS would support evaluation of resources utilizing PCAP methodology in the future, but is supportive of the current UCAP at this time. 

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 No comment at this time.

Please include section numbers throughout the document.

These capitalized terms are not defined in the tariff or BPM105 (there are probably more, here is a sample):

1. WPP Data Instruction Manual
2. Data Instruction Manual
3. Max Capacity (In Table 1, ESR section)
4. Advanced Assessment Data Request
5. Hydro QCC Workbook
6. Cascaded Dual Plant