City Light has no comments on this section of the BP.
No response submitted.
No response submitted.
- Capability Test Requirements for Thermal Units - Is this a standard from someplace else? Or was this created by WRAP? If it is someone else’s standard (such as NERC) why wouldn’t we point to that standard, if they go through the public process to change the standard it would automatically be reflected in the WRAP standard, and not require us to go through a PBM update?
July 14, 2023, 12:41 p.m.
Powerex would suggest this section clarifies that only thermal resources utilizing the Equivalent Forced Outage Factor methodology are subject to providing a capability test. If a thermal resource is not dispatchable by the participant, but the participant is required to take 100% of the output of that resource, the QCC could be determined by another method utilizing the average output in Capacity Critical Hours. In this case, the resource would not need to provide a capability test.
Capability and Operations Tests of thermal resources sections not reviewed.
Please provide additional definition of the term Test. For example, is a Test satisfied simply by providing historical data that shows when a generator performed to a certain output amount under a given set of conditions? Or are there additional procedural requirements?
No response submitted.
What is MOD-25? Or include of footnote of where to find this information.
For thermal capability test - why not use historical peformance with temperature data?
Why does thermal have a capability test as well as an operational test as opposed to just an operational test like the rest of the resource technologies?
Since the capability test is utilized for the base UCAP calculations it would be good to highlight that this test is needed ahead of the Advance Assessment if a participant would like it to be used in calculation of QCC. That a test done after the Advance Assessment deadline would not amend the base UCAP calculation for the resource.
APS generation engineers wanted to clarify if the ASHRAE Rated Ambient Temperature is the same as Design Temperature? Also, in the out of season capability testing section the document references a “Operational Test procedures” is that something that will be contained in another BPM or should it be added to this BPM as an Appendix or section?
NV Energy appreciates the opportunity to comment on the Qualifying Resource BPM and offers the following questions with the intention to get clarification written into the BPM:
- Should participants inform the program operator in advance of any capability tests, or would the participant be allowed to schedule and perform at their convenience?
- Will a registered resource have the option to perform and resubmit a capability test within the 5-year window, if desired?
No response submitted.
Is this BPM intended to set the deadline for submitting Generator Testing information? We don’t see a specific deadline or process for submitting Capability Testing information.
To the greatest extent possible, generator testing requirements should allow Participants to use results from other required regular testing (i.e., MOD-025). For example, Capability Testing requirements should be able to be met with MOD-025 testing results.
If a resource is co-owned by multiple Participants, test data submitted by one Participant should suffice to meet the requirements of both if the other Participant(s) do not perform that testing individually.
No response submitted.
In this section it would be helpful to describe why there is a need for two different tests and the usefulness of each in the program design. Do the Operational test or the Capability test limit the PO modeled QCC? If so, clearly specify how they limit (For ex., Final accredited capacity = Minimum (PO modeled QCC, Capability Test / Operational Test MW)
MOD-025 test based capacity is influenced by the temperature on the day that the testing occurred. For thermal resources, there can be significant differences in capability as a function of ambient temperature derates. As a result, utilizing MOD-025 tests which are conducted on random days of a year for establishing capability will lead to very inconsistent Thermal capability used for establishing LOLE/PRM for the footprint. It will also make it challenging for participants with significant Thermal resources to claim their full Thermal Capacity values for the purposes of meeting their forward showing requirements.
This section presumes that MOD-025 is the appropriate method for establishing Thermal capability and that it is acceptable to perform these tests multiple times a year. Our discussions with plant engineers indicates that there is a reason this test is conducted once in five years, as the testing process results in numerous unit trips. Given that many participants have their resources in organized markets, it is either infeasible or very uneconomical to introduce the risk of unit tripping and the burdens of additional MOD-025 tests (one for the Winter and one for the Summer).
The feedback we get from our plant engineers is that MOD 32 is the proper test for thermal capacity calculation as it is calculated based on assumed ambient temperatures. PSE appreciates a discussion (perhaps in the FS Workgroup) regarding the best practices for establishing Thermal capability before making it a part of the BPM.
Some considerations include:
- Does it make sense to establish temperature standards by zone and then determine the Thermal capability based on the established temperature standard?
- Does it make sense to establish a consistent percentile based methodology utilizing historical data ?
Is the description of the Capability Test developed by WRAP? If not, simply provide outside reference. Otherwise it looks like WRAP is prescribing/defining these requirements and enforcing penalties.
Spell out first instance of UCAP (Unforced Capacity).