01: Please supply any comments related to the Introduction, Definitions, or Background sections.

APS has identified some inconsistencies in the definition of LOLE Study and the description used throughout the body of BPM 102. The definition says it is a “…single event day of loss of load in ten years reliability metric for each Month of the Binding Seasons, while in Section 2 & 5 “…no more than a single event-day of loss of load in ten years during the Binding Seasons, in Section 7 as “... one event-day in ten years reliability threshold.”, and in Section 8 inside the FSPRM calculation the UCAP 1-in-10 “…UCAP required to meet the reliability for a specified Month in a Binding Season. It is hard to clearly understand what the metric is when we say 1-in-10 with varying definitions.

The term Load Data should be changed to Historical Load Data to reflect the final approved version of BPM 101 and its associated Definitions.

02: Please supply any comments related to the Study Scoping Process section (3).

APS suggests that we define the “timely opportunity” better for the Board and RAPC review of the LOLE Study Scope. Previously, it has worked well to have the RAPC informed at a meeting and then final scope decided at subsequent meeting.

03: Please supply any comments related to the Load and Resource Zones section (4).

APS recommends that additional information be put in the BPM on the reason LRZs are utilized in the LOLE Study, it is unclear to us the benefit they provide over just making the sub-regions of the WRAP footprint as (2) LRZs. Also, we think footnote 2 can be deleted as it looks like a duplicate of footnote 1.

04: Please supply any comments related to the Load and Resource Zones - Subregions Used for Determination of Monthly FSPRMs section (4.1).

At the bottom of Section 4.1 it mentions WPP will assign new Participants to a Subregion – Is there a reason we don’t have the new Participant self-select and the WPP approve the self-selection? It seems an interested Participant may be dissuaded from joining if they are not allowed to determine the sub-region they participate in, assuming they could participate in multiple. 

05: Please supply any comments related to the Load Modeling in the LOLE Study section (5).

APS seeks additional information and perhaps an example of how the weather and load 40-year synthesized profiles are performed, particularly if there is a check by Participants of profiles that are developed as a sanity check. Also of interest would be the associated impact of using LRZs to create weather and load profiles and whether it masks or does not mask the Program’s ability to see correlation of weather and load effects on the wider footprint than the LRZ (i.e. west wide heat wave)?

It is not specific as to whether Load Data is “raw” data or adjusted for DR events or behind the meter generation, and APS would ask that the BPM reference BPM 101 Advance Assessment in this area as to the details of the Load Data. 

Table 1 (referred in the body as Table 3, needs correction) shows examples of weather station locations.  It lists Scottsdale, Arizona as one location.  Sometimes examples get taken literally, APS suggest changing to Phoenix Arizona, which has much more robust historical weather data in case someone uses the example as a required location. Alternatively, the removal of the SW&E Subregion (or full Table) from the Table could be performed as it appears the Table is only used to illustrate the usage of backup stations.

06: Please supply any comments related to the Generator Modeling in the LOLE Study section (6).

APS requests more clarity on the capacity transactions resulting in either a net import or export. This says they would be modeled as generators, is that true for exports? Or would exports be modeled as load? There is more detail in Section 6.9, but it refers to exporting capacity and maintains modeling as a generator. Is there associated FSPRM or FS Capacity Requirements associated with these transactions in and out of the WRAP Region.

07: Please supply any comments related to the Generator Modeling in the LOLE Study - Thermal Generator Modeling section (6.1).

In Section 6.1 it refers readers to BPM 101 Advance Assessment for details related to the Capability Test, however there is not details in BPM 101 on the Capability Test. APS commented on BPM 105 where the details of the Capability Test are located that they should be included in BPM 101, but they were not included. APS comment on BPM 105 question 9 in the template reads, “Please supply any comments related to the Resource Registration – Provision of Test Reports in the FS Submittal section.

APS believes the Capability Test should reference submission at the Advance Assessment in this paragraph, the way it reads makes us believe there is a capability test submitted at the FS Submittal which is false.”

08: Please supply any comments related to the Generator Modeling in the LOLE Study - Storage Hydro Qualifying Resources section (6.2).

No comment at this time.

09: Please supply any comments related to the Generator Modeling in the LOLE Study - Wind Resources section (6.3).

This section says that wind resources in a LRZ will be modeled together as one resource.  Each wind resource has a different production profile depending on design and location.  From our understanding the production profiles for each resource will be factored into the modeling process.  If this is correct, suggest adding the words in quotes to make it clear. Wind resources provided by Participants will be modeled together as a single wind Resource per LRZ in the LOLE Study “utilizing the individual resource profiles described herein”.

10: Please supply any comments related to the Generator Modeling in the LOLE Study - Solar Resources section (6.4).

 

This section says that solar resources in a LRZ will be modeled together as one resource.  Each solar resource has a different production profile depending on design and location.  From our understanding the production profiles for each resource will be factored into the modeling process.  If this is correct, suggest adding the words in quotes to make it clear. Solar resources provided by Participants will be modeled together as a single solar Resource per LRZ in the LOLE Study “utilizing the individual resource profiles described herein”.

The word “wind” should probably be “solar” in this sentence.  “The Program Operator will identify in the Study Scope whether synthesized wind shapes for years where historical data is insufficient or not available will be redetermined for the upcoming LOLE Study”.

11: Please supply any comments related to the Generator Modeling in the LOLE Study - Energy Storage Resources section (6.5).

No comments at this time.

12: Please supply any comments related to the Generator Modeling in the LOLE Study - Run of River Qualifying Resources section (6.6).

No comments at this time.

13: Please supply any comments related to the Generator Modeling in the LOLE Study - Demand Response Programs section (6.7).

Is DR last in the dispatch as stated, or is ESR in “preserve reliability mode” last in the dispatch stack?

14: Please supply any comments related to the Generator Modeling in the LOLE Study - Behind-the-Meter Generation section (6.8).

No comments at this time.

15: Please supply any comments related to the Generator Modeling in the LOLE Study - External Capacity Modeling section (6.9).

APS is wondering if there is more information about this interchange amounts, like how exactly does this show-up? Is it better to say an additional MW of capacity to the capacity requirement? Or is it more in the load value that we are solving for load + exports?

16: Please supply any comments related to the Generator Modeling in the LOLE Study - Contingency Reserves Modeling section (6.10).

Typo “sever” needs changed to “severe” in Section 6.10 (i).

17: Please supply any comments to the LOLE Study section (7).

No comments at this time.

18: Please supply any comments to the FSPRMs Calculations section (8).

No comments at this time.

General Comment