Recommend changing the deadline for registering resources to 120 days prior to the forward showing submission date.  Requiring registration of resources for QCC 15 months ahead of time is unreasonable and unworkable for most resource development / resource procurement timelines.

Shell Energy strenuously opposes the normal resource registration timelines which requires 18-month to 24-month lead times in advance of being eligible for WRAP RA.  This does not reflect the manner in which new resources are developed and attain commercial operations, nor reflect the contracting realities of prospective non-utility WRAP participants.  For instance, presuming registration is required post-COD, this would lead to a roughly 18-month delay between a resource COD and realizing capacity value under WRAP.  This would unnecessarily increase costs for end users.  The normal timeline should be more abbreviated, Shell Energy would suggest resources registered and validated be eligible to realize WRAP capacity value for the prompt FS period, requiring registration 7-8 months in advance of a FS period.

• What happens if you contract after this deadline?   Should provide ability to add resources X (3?) months prior to the season it will be used?
• In the table, item, 'Ownership or Contracted Percentage for Participant' - Resource registration is part of advance assessment - this isn't needed until FS is it? Need clarification please.
• In the table, item, 'Summer Max Capacity or Nameplate (MW)' - Should this be an 'or' vs. 'and'? - same with the 'Winter Max Capacity or Nameplate (MW) item
• Table 2 - Thermal Resources, last sentence, '...as post in an appropriate location on WPP website.' - is very vague. Is there a link available?
• Table 2 - Wind, ROR Hydro, Solar Resources - Why are they requiring annual data when we only really care about capacity critical hours during the summer and winter seasons.  E.g. Using annual generation data may lower the capacity factor b/c we load factor to save water for HLH. 
• Table 3 - 'Ownserhip or contracted % for participant' - Resource Registration is part of Advance Assessment – this isn’t needed until Forward Showing is it?  Need clarification

• Powerex suggests that a table be included in this section, specifying all of the critical due dates for the Forward Showing data submission. The dates would be relative to the start of the Summer or Winter binding seasons.
• Page 4: “The registration process for all Qualifying Resources, other than Storage Hydro Qualifying Resources, will require, but will not be limited to, the items set forth in Table 1, Table 2, and Table 3...”
• Powerex believes this sentence should be reworded, to be clear that Storage Hydro resources are subject to Table 2 and 3 only.
• Table 2 requires thermal resources to submit GADS data so SPP can calculate forced outage rates. However, there is no requirement for Storage Hydro resources to submit GADS data. Historically, participants have been asked to submit GADS data for Storage Hydro resources as part of the SPP Study Data Request. Powerex suggests the language be clear for the requirement of Storage Hydro resources in providing their GADS outage data.

Please post the Advance Assessment data request workbook.  It might make sense for the guidance and instructions in the WPP Data Instruction Manual for providing resource registration information be part of this business practice as opposed to appearing in a separate document that content may be relevant to this business practice.

• Resource Registration – Page 3 – Resource Eligibility and Timelines:  The work ‘All’ should be removed from the first sentence!  Participants should have the ability to register resources as they determine, if they have a resource that they do not wish to register or make available that is (should be) their own discretion, stating ‘ALL’ takes that out of the participants hands.  Rules defined in this BPM already describe late registration and require that it be newly acquired and to show that, as a result a resource not submitted couldn’t be added for Forward Showing because the party is short, this is participant decision.
• In Table 1 – page 5 – and Table 3 – page 7 - 'Ownership or Contracted Percentage for Participant' - Resource registration is part of advance assessment – Participant share isn't needed until Forward Showing, why is this part of resource registration.

APS has a question regarding the treatment of resources owned and operated by entities that are not participants and specifically if they are eligible for the late registration of resources in the following section, since this section notes, “Resources owned and operated by entities that are not Participants and contracted to Participants with unit or resource specific contracts (i.e., not system sales or block contracts) must be registered with the PO and provide necessary data in order for Participants to claim QCC from these resources toward their Forward Showing Capacity Requirements.

 No comment at this time.

Please outline the process and timelines clearly (For example, what is the duration and frequency of the advance assessment?) What are some considerations to shorten these timelines? How does this align with Section 14.3 in the Tariff?

Please list out all outcomes of not meeting resource registration deadline, up to and including the usage of discounted QCC

Clearly specify if the Advanced Assessment establishes all or some of  QCC, PRM, LOLE, and how the registration/advanced assessment deadlines align with PRM determination as defined in the Tariff section 14.3. See the table below for a sample of timelines based on the Tariff. In this example below, the advance assessment deadline for Summer 2026 is after the deadline for the PO to issue the recommended PRM.

Advance Assessment deadline from BPM 105: Summer 1/31/2025, Winter 1/31/2025

Tariff Recommended PRM: Summer 11/1/2024, Winter 4/1/2025

Tariff Final PRM:                 Summer 2/1/2025, Winter 7/1/2025

Tariff FS deadline:              Summer 11/1/2025, Winter 4/1/2026

Example season begins:     Summer 6/1/2026, Winter 11/1/2026

For “Resources owned and operated by entities that are not Participant”, instead of 'resources ... must be registered' specify who will register resource.

In Tables 1 and 3, explain why are PPAs with another participant excluded from listing the contracted percentage?