Only allowing 10% of late registered resources appears arbitrary and a barrier for entities to join.  City Light suggests allowing 75% of late registered resources.

Shell Energy appreciates the ability to utilize a late resource registration option inside the proposed 18-month window; however, limiting the resource to providing a maximum of 10% of an LRE's FS capacity requirement is without merit. For instance, should a LRE count any one resource to provide a majority of the LRE's FS capacity requirement, under the proposed BPM the LRE must contract for additional capacity -- at great expense burden to the LRE's customers/ratepayers.  Shell Energy suggests this 10% limit be subject to a waiver process should WPP and the RAPC find this threshold is demonstrably essential.

Especially for new builds, development of said incremental resources require a level of quality and sophistication likely meeting the reliability standards of an RA program; said another way, Shell Energy believes almost no resources under development today will be unreliable jalopies. Accordingly, the 10% threshold is too conservative and not fit for purpose.

Powerex notes that utilizing a class average for Storage Hydro resources is problematic and would be difficult to apply in practice. Different hydrological conditions, reservoir limitations and size, and non-power constraints will vary by project. We suggest that for Storage Hydro resources, given their unique nature, the Participant can propose a methodology consistent with the Storage Hydro methodology for calculating the QCC of the resource. The modelling approach will be reviewed and approved by the Program Administrator. If the proposed methodology is approved, the Program Administrator can accept the late registration of a Storage Hydro Resource. For example, a new project downstream of an existing Storage Hydro project could utilize the QCC results of the existing project, adjusted proportionally up or down to the nameplate capacity of the new project.

For the use of terms in quotation, (e.g., ‘class average’ or ‘discounted’) please either define them as terms in a Definitions Business or consider replacing with a plain language description.

Please include the WPP Data Request Instruction Manual as part of business practices and supporting forms.

• Note that utilizing a class average for new Storage Hydro resources is problematic and would be difficult to apply in practice. Different hydrological conditions, reservoir limitations and size, and non-power constraints will vary by project. Propose somethgin on the line of participant can propose a methodology consistent with the Storage Hydro methodology for calculating the QCC of the resource.  Modelling approach will be reviewed and approved by the Program Administrator/Program Operator.

Table 1 - spell out ESR in the description

 

See comment on question #2.

 No comment at this time.

  For the Ownership Percentage, why is there a difference in treatment between "Contracts" and "Resources"?