04: Please supply any comments related to redlines to Tariff sections 14.2.1.2, 16.1.5, and 19.2 (relating to Forward Showing Submittal demonstration of inter- subregional transmission in lieu of Capacity)




July 8, 2024, 2:45 p.m.
RAJ HUNDAL | PWX
No response submitted.

July 9, 2024, 8:18 a.m.
BEN BRANDT | Idaho Pow…
No response submitted.

July 9, 2024, 9:54 a.m.
JERRET FISCHER | SRP
No response submitted.

July 9, 2024, 11:20 a.m.
MATT HAYES | BPA

16.1.3 – Recommend that the tariff not use “program” in “A Participant’s demand response or load reduction program”. This is not a defined term and is not used elsewhere in the tariff.

Recommend using the word “applicable” rather than “certain” when discussing testing requirements.

Regarding the following sentence: “the Participant or by the host utility, and which has met certain testing requirements consistent  with Business Practice Manuals…”: BPA requests that WPP clarify if “consistent” is being used to allow for testing requirements different from those in the BPMs, but still acceptable to WPP. If not, “consistent” may offer more flexibility than WPP intends.

Request for clarification: The QCC of what? The subject of the first sentence is “program”. This is the only section that uses the phrase “demand response program” or “load reduction program” and neither of those phrases are defined. Please clarify specifically what is the subject of the QCC calculation. Additionally, should this sentence on determining QCC be in section 16.2?
 

“A Demand Response Load Modifier’s QCC is subtracted from the P50 Peak Load Forecast” – BPA suggests “is” be changed to “shall be”
 

“…nothing prohibits a Participant from using an existing demand response or load reduction program that does not satisfy the requirements for Demand Response Capacity Resources…” Should this be in the “Advance Assessment” section? E.g. “Participants may use a demand response or load reduction program that does not satisfy the requirements of DRCR or DRLM in their advance assessment”?

In addition, DRCR has its own section: 16.2.5.4., which contains much of the same information. BPA recommends that this section just point to 16.2.5.4


July 9, 2024, 11:43 a.m.
BEN BRANDT | Idaho Pow…
No response submitted.

July 9, 2024, 3:01 p.m.
SACHI BEGUR | Puget Sou…
No response submitted.

July 9, 2024, 4:12 p.m.
TYLER MOORE | Arizona P…

No comments at this time.