In sections 16.1.3 and 16.2.5.4 The method to determine QCC for Demand Response seems to be inaccurate if the resource can be deployed for longer than five hours. For example, as it reads in the draft language now, a 10 MW demand reduction resource that can be deployed for 20 hours would receive 40 MW QCC (10 MW X 20 hours/5). Powerex suggests that in the calculation, the number of hours a resource can demonstrate load reduction be capped at a maximum of five. 

16.1.3 “and which has met certain testing requirements” Not comfortable with this language, this could be interpreted to mean some type of “test” is required in the BPM. This should be deleted, or different language offered that creates multiple pathways to ensuring a Participant can get appropriate credit for their DR program. Additionally, programs may change from year to year and a “test” may not be allowed or accurate unless completed well after the FS cure period is over. Substantially more latitude is required to accurately capture the value of DR programs. There is little if any incentive to overstate the value and if an entity does overstate the value it will result in additional holdback or loss of delivery for the entity resulting in financial impacts in the Operations Program. This language is unnecessary and will result in reduced credit or no credit for DR programs that are encouraged, even required by a number of PUCs. It is important that each MW of capacity is accounted for accurately, Participants are highly incented to get their FS submission correct and will not be able to do so with overly burdensome or unnecessary testing requirements.

Please explain how it has been determined that the QCC calculation is appropriate for all DR programs in the region. Does this calculation belong in the tariff, or should it be in a BPM? Should the Participant be allowed to submit their own QCC value for the DR program or is there another mechanism to ensure the program is properly valued?

16.2.5.4 Please explain how it has been determined that the QCC calculation is appropriate for all DR programs in the region. Does this calculation belong in the tariff, or should it be in a BPM? Should the Participant be allowed to submit their own QCC value for the DR program or is there another mechanism to ensure the program is properly valued?

SRP has provided comments to proposed BPM 103 to advocate for capacity value parity between participant election for Demand Response treatment.

SRP would prefer that the QCC determination be handled in a business process manual, perhaps capped in the tariff by “multiplying the load reduction in MWs by the number of hours the resource can demonstrate load reduction capability divided by five.”  Specifics of Demand Response programs (such as the number of times that a program can be utilized in a week or a year) may limit QCC beyond the calculation in the tariff language. Retaining the ability to consider these details in QCC calculations without a tariff revision may be valuable to WRAP.

SRP recognizes that SRP’s preferred tariff treatment of DR QCC would be a departure from existing tariff language intent, and SRP is willing to support the collective proposed revisions, deferring additional revision to other processes.

16.2.5.4 seems to convey the same information as 16.1.3, but in a more clear and concise manner. Recommend modifying section 16.1.3 to point to this section rather than restating the information.

Section 16.2.5.4 should point to where the discussed testing requirements will be articulated.

If this language – “and which has met certain testing requirements consistent with Business Practice Manuals” – is referencing testing requirements outlined in BPM 105, it is Idaho Power’s understanding that capability and operational testing requirements specified in BPM 105 are only applicable to Demand Response Capacity Resources, not Demand Response Load Modifiers.  BPM 105 states, “A DR Qualifying Resource [which is subject to capability and operational testing] will be reflected in the FS Submittal as a capacity resource by submitting it as a ‘Resource’ in the FS Submittal. As with all resources, the QCC value of the DR Qualifying Resource will count toward a Participant meeting its FS Capacity Requirement.” The reference to testing requirements in the Tariff for Demand Response Load Modifiers seems contradictory to the testing requirements outline in the BPM.

See comments on BPM 103 for thoughts on section 16.1.3 and potential reliability impacts of not adding the FPRM on the load reduction allowed with load modification option.