City Light has no comments on this section of the BP.

• Storage Hydro Resources - 2,3, & 4th sentences - Question if the previous season is the correct.  For Thermal units we say once every 5 years, for storage we are only giving a single point in the previous season – this should probably be on equal footing – previous 5 years (applicable to the correct season).  If last year was an extremely dry year, or had a flood of other resources available on the market someone may have chosen to not operate at peak levels..  which in theory as written could cause a limitation in the following years WRAP QCC  under this test…  This should be over multiple years to not create that issue.
• ESRs - ESR, ROR, Wind/Solar do got give a data range for operational test..  Thermal says 5 years, Storage says same season-previous year…    These all should be on the same time frame requirement and should be greater than 1 year – recommend 5 years (could be rolling – so updated every year), but needs to be greater than a single season/year in order to make sure you haven’t experience an anomaly – or you then have to write the additional rules around dealing with the anomaly

Powerex would like to understand why the Operational Test for Storage Hydro resources must achieve a minimum of 90% of the highest monthly QCC value from the Participant’s current and previous seasons FS submittal. Powerex believes that the monthly QCC numbers the Operational Test is performed against should apply to the Forward Showing being completed.

• Storage Hydro Resources - Need to clarify that operational test can be conduct at plant level (aggregate of multiple units in single facility), however outages and derates need to be included at the individual unit level.
• Run of River Hydro – should be ‘project’ or ‘plant’ and not ‘unit’

ESRs - no metric is included for ESRs. 90% for the consecutive duration seems reasonable in order to ensure it'll perform as expected in a peak event.

 

Is the Net Generating Capability the value that is set every 5 years by performing the Capability Test? If so could this section be re-worded to state, “The Operational Test must be conducted at a minimum of 90% of the summer Net Generating Capability Capability Test.”?

APS has a resource that is thermal energy storage paired with solar, and believes that it would be included in the testing requirements for ESRs. Would this type of resource be considered in the ESRs section for testing purposes?

Operational testing requirements should be flexible to account for a variety of operational and hydrological conditions.  There are a number of variables that may need to be taken into account when scheduling operational tests, and at a minimum the testing should allow for use of historical data within the relevant period.

It is the understanding of SRP that jointly owned resources, outage data, and testing are the responsibility of the plant operator. SRP encourages the WPP to clarify the need for rules for jointly owned resources to be explicitly defined in the BPM.

Please clearly state the need for two tests - Capability and Operational and the differences and use cases for each of these tests.

Please clearly state how these test are to be performed. Is this test similar to the MOD-25 test based on NERC standards or is this a PA/PO established test. Identify use cases, duration and frequency for these tests.

For Thermal resources the documentation states “Any hour with the unit operating at or above 90% of the Net Generating Capability may be deemed a successful Operational Test.” Since thermal plants produce less in the Summer compared to Winter due to ambient temperate derating, please clarify why the thermal tests are not seasonal.

With regards to the following reference, please clarify “previous seasons”

“Test data shall be compiled and submitted via the FS Submittal process, as outlined in BMP 108 Forward Showing Submittal. The Operational Test must achieve a minimum of 90% of the highest monthly QCC value from the Participant’s current and previous seasons FS Submittals.”