No response submitted.
No response submitted.
NV Energy appreciates the opportunity to comment in the Western Power Pool’s (WPP) Business Practice Manual process and offers the following comments for consideration. Section 3 provides the specific details for the sharing calculation along with the sharing calculation equation. The program uses forecasts to receive the most up to date availability for Variable Energy Resources and Run of River resources and uses forced outage data to determine the availability of thermal and storage hydro resources. Therefore, is it possible for a thermal resource or storage hydro resource to be considered to have more availability than the QCC amount used in the Forward Showing like Variable Energy Resources? If thermal resources are always capped to the QCC amount in their Forward Showing, then NV Energy would be concerned that the program maybe discrediting thermal resources in the operational program.
SRP’s comments for BPM 103 regarding an interest in parity between Demand Response treatment paths are also applicable for BPM 202.
SRP understands that consistent with section 20.1.1 in the tariff, the Δ Forced Outages list includes lost capacity from thermal resources and storage hydro resources, but does not include Energy Storage Resources (or Demand Response capacity resources). SRP requests guidance for how the sharing calculation can include legitimate loss of capability reflected in a Participant’s Portfolio QCC resulting from forced outage of Energy Storage Resources.