Powerex notes that the Sharing Calculation now includes both a Contingency Reserve Adjustment term, and a Contingency Reserve Obligation term. In order to ensure that Participants can accurately calculate these two terms, it is recommended that the WPP make available a numeric example. 

Powerex notes that the Uncertainty Factor definition is included twice. 

“must satisfy 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.

SRP is concerned that Demand Response Load Modifier treatment enjoys an unwarranted capacity benefit beyond Demand Response Capacity Resource treatment due to avoided planning reserve requirement.  SRP does not believe that electing to treat demand response resources as load modification would have a legitimate resource adequacy benefit over capacity resource treatment, and SRP strongly advocates for algebraic parity in the sharing calculation between the two treatment methods.  SRP has provided related comments in response to the draft BPM 103.

SRP supports the other formulaic corrections in the Sharing Calculation, especially including the inclusion of a participant’s full Contingency Reserve Obligation.

SRP advises that the definition for Uncertainty Factor appears to be errantly included twice in the definition list.

“Demand Response Load Modifier, as described in Section 16.1.3, refers to Demand Response…”: BPA requests definition clarity and consistency from WPP regarding use of the term “Demand Response”. This term is defined as a “resource” in the definitions section, and as a “program” in 16.1.3. Here it referred to simply as “Demand Response” – which is not defined anywhere.

Request that WPP identify the actor and demonstrable action in this provision that a participant did not identify in their load profile or in their FSCR submittal.

“A Demand Response Load Modifier must satisfy all testing requirements applicable to a Demand Response Capacity Resource, but is used  to reduce P50 Load Forecast rather than as a Qualifying Resource;”: please confirm that this is also needed for the equation above this sentence.

“Load Forecast refers to the forecast of expected load for the subject hour for the loads for which the Participant is responsible;”: Suggest revising to: “…refers to the Participant’s forecast of expected load for the subject hour for the loads for which the Participant is responsible.”

Demand Response Capacity Resource - Request 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.

The Sharing calculation formula likely contains an incorrect sign with regards to the DR Capacity resources.

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