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

Is it an issue that ESRs can qualify with 2-4 hours of discharge but DR must be deployed for 5 hours to qualify? Should the treatment of ESRs and DR be consistent?

“The QCC value of the DR Qualified Resource is determined by multiplying the load reduction in MWs by the number of hours the resource can demonstrate load reduction capability divided by five” We are not sure we understand the mechanics here. For a DR resource that is capable of reducing demand for 5 hours this seems pretty straightforward, but what about a resource that is capable of demonstrating 20 hours of a 5MW reduction? Am I understanding correctly that it will get credited with a 20MW QCC despite only being able to provide 5MW? 

“Testing for new DR programs in their first year of operation will be allowed if the Participant intends to claim QCC of more than 50% of the expected capability.” This was confusing to me. Is the program determining the QCC of the DR or is the Participant determining it? The previous section provided the calculation for determining the QCC, but this section seems to suggest that a Participant might claim a QCC of less than that. 

Why does the Operational Test only require the DR program to achieve 50% of the stated capability? And for only 1 hour rather than the 5 hours it claims to be able to perform?

If DR is included in load, it effectively receives a 100% QCC and reduces the PRM requirement.  New DR only qualifies for QCC based on five continuous hours (so could be less than 100%) and therefore is not equivalent in its capacity benefits. to ensure the greatest reliability, DR should be removed from historical load and the load forecast and only included as a resource? Further the 5 hour method should be replaced with an ELCC approach.  

 

APS believes the wording saying “up to 5 hours” in the first paragraph is unclear. Does this mean a program that is more than 5 hours is not eligible? We believe that it is suppose to say that QCC will be based off the performance of the DR over 5 hours.

 No comment at this time.