WPP

July 10, 2023, 2:09 p.m.

MICHAEL WATKINS | Seattle C…

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

July 3, 2023, 2:26 p.m.

IAN WHITE | SE

No response submitted.

July 11, 2023, 7:50 a.m.

WILLIAM GODDARD | Calpine E…

No response submitted.

July 13, 2023, 2:50 p.m.

KATIE NELSON | BPA

Under 'Allocation of ELCC for ESRs (Pg. 26), 2nd sentence - Sentence feels confusing – ‘All’ feels like the wrong way to describe it, since a Two-Hour rated ESR doesn’t get the same rating. Maybe something like – ‘ESRs across a Subregion will receive the average ELCC based on the ESRs hour rating (see above Four-Hour and Two-Hour rating descriptions)

July 14, 2023, 12:41 p.m.

CONNOR CURSON | Powerex

Powerex notes that the Operational Test for Energy Storage Resources is missing details on what constitutes a successful test.

July 17, 2023, 3:37 p.m.

LEAH MARQUEZ-GLYNN | Tacoma Po…

What is the rationale for limiting the 2-hour storage QCC value to 50% of the 4-hour storage QCC? We would not necessarily expect ELCCs to be linear based on the duration of the storage. Why does the ELCC study itself not determine the QCCs?

July 18, 2023, 8:54 a.m.

KATIE NELSON | BPA

Allocation of ELCC for ESRs – page 26 – second half of paragraph is referencing both ESRs and VERs, does this need to be in its own section clearly calling out this methodology to assure over-accreditation doesn’t happen?

July 18, 2023, 9:28 a.m.

LORI HERMANSON | Avista

What's the justification of using 50% of the 4-hr QCC?

July 18, 2023, 1:42 p.m.

TYLER MOORE | Arizona P…

Related to the comments in #6 above APS has a thermal energy storage resource, and this section calls out pumped storage and battery storage, but does not include thermal energy storage. APS believes that this should be added as a valid energy storage resource.

b) Are batteries held to the mode of preserving reliability in the advanced assessment at the time of PRM establishment as well? It would be helpful to note that the assumption is the same or different between the PRM setting and ELCC methodology.

c) How would longer than 4 hour duration storage be treated?

July 18, 2023, 3:02 p.m.