Demand Response Capacity Resource: Please explain the intent of the phase “utilize exclusively to meet a Participant’s FS Capacity Requirement”. Specifically, How is this expected to impact a Participant’s ability to claim DR in their FS? Will this increase the data submittal burden to prove exclusivity? Will this elevate the bar for claiming DR making it difficult to get credit for DR programs in the FS? If the answer is that this will not make it more difficult to get credit for DR programs, please explain why with BPM and tariff references.

Demand Response Load Modifier: What does “demonstrated mean” where are the demonstration requirements outlined? Please explain the intent of the phase “utilize exclusively to meet a Participant’s FS Capacity Requirement”. Specifically, How is this expected to impact a Participant’s ability to claim DR in their FS? Will this increase the data submittal burden to prove exclusivity? Will this elevate the bar for claiming DR making it difficult to get credit for DR programs in the FS? If the answer is that this will not make it more difficult to get credit for DR programs, please explain why with BPM and tariff references.

The definition of “Central Hub” may benefit from clarification that the WRAP program identifies central hubs, and that they are not solely the result of an examination of the physical transmission network.

SRP encourages clarification if the Aggregate Capacity Deficiency is intended to be calculated for each month within a binding season or if is it intended to be coincident.

Central Hub: This definition should not use the term it is trying to define in the definition. Central hubs do not permit energy delivery. It is a point where energy transactions can be made. Suggested revised definition: Designated points on the transmission system in the particular sub region where WRAP transactions can be facilitated.

Demand Response Capacity Resource: BPA requests that WPP use more precise, but less restrictive, language than “utilized exclusively.” E.g. “is accounted for in,” or “is identified/designated in”. “Utilized” is too vague when resources are discussed in terms of both physical assets and numeric values. “Exclusively” introduces questions of scope.

Demand Response Load Modifier: BPA requests clarity from WPP on the following: Section 16.1.3, titled “Demand Response Load Modifier,” begins: “A Participant’s demand response or load reduction program, which must be controllable and dispatchable by the Participant or by the host utility, and which has met certain testing requirements consistent with Business Practice Manuals.”

Is this definition and section 16.1.3 consistent? If yes, should they be combined?

Also for the Demand Response Load Modifier when using the phrase “utilized exclusively”: request WPP use more precise, but less restrictive, language than “utilized exclusively.” E.g. “is accounted for in,” “is identified/designated in”. “Utilized” is too vague when resources are discussed in terms of both physical assets and numeric values. “Exclusively” introduces questions of scope.

Holdback Capacity: BPA found this definition confusingly and similar to definition for “Voluntary Holdback”. Request that WPP make a clearer distinction between these two terms.

System Sale:  “Fleet” seems out of place. Is it here to clarify that the capacity/energy is coming from generation resources owned by one of the parties as opposed to the conveyance of rights to capacity/energy? Or, is it to replace the “two or more” language in the previous version? The Change Request Form says this definition was modified to eliminate “Qualifying Resources” to allow for purchases by participants from non-participants with unregistered resources.

Is the phrase “from a fleet of generating resources” necessary? The term is ambiguous and should be avoided unless serves a clear purpose.        

Additionally, the following revision to the definition is suggested: bilateral agreement that conveys generating capacity and/or energy from a fleet of generating resources from one party to another.

Voluntary Holdback: the first sentence of this definition is confusing. Please consider revising to simplify it. Also, suggest moving the last sentence of this definition to section 19.4, it is unusual to see a requirement imbedded within a definition.

APS has some comments surrounding the definition and concept of Demand Response Load Modifier that were submitted on BPM 103 and we look forward to the updated version of that BPM.