01: Please supply any comments related to the Introduction or Definitions sections. (1)
No response submitted.
02: Please supply any comments on the Demand Response Utilization section. (2)
Powerex generally supports the inclusion of Demand Response (DR) in the WRAP program in a manner that is consistent with its actual performance capabilities.
Draft BPM103 provides an option for a WRAP participant to incorporate its DR as a Monthly P50 load modifier. It appears that this methodology could have the effect of overstating the DR’s capacity contribution if the participant’s requirement is reduced by both (a) the DR’s capability and (b) the PRM that would have otherwise applied to the load that is reduced by the DR.
Powerex recommends exploring alternatives that could reduce or prevent the potential for this outcome. Options could include establishing limitations on when this approach could be used (e.g., when data is not yet available to use another approach) or to make an adjustment to the load modifier to account for the potential impact to the participant’s PRM.
03: Please supply any comments on the FS Capacity Requirement section. (3)
No response submitted.
04: Please Supply any comments on the P50 Peak Load Forecast section. (4)
No response submitted.
05: Please Supply any comments on the P50 Peak Load Forecast - Winter P50 Peak Load Forecast section. (4.1)
No response submitted.
06: Please Supply any comments on the P50 Peak Load Forecast - Summer P50 Peak Load Forecast section. (4.2)
No response submitted.
07: Please supply any comments on the Load Growth Factor section. (5)
No response submitted.
08: Please supply any comments on the Load Growth Factor - Established Growth Rate section. (5.1)
No response submitted.
09: Please supply any comments on the Load Growth Factor - Participant Alternative Growth Rate section. (5.2)
No response submitted.
10: Please supply any comments on the Contingency Reserves Adjustment section. (6)
No response submitted.
11: Please supply any comments related to the Contingency Reserves Adjustment - Contingency Reserve Adjustment-Generation section. (6.1)
No response submitted.
12: Please supply any comments related to the Contingency Reserves Adjustment - Contingency Reserve Adjustment-Load section. (6.2)
No response submitted.
13: Please supply any comments related to the Excluding Load section. (7)
No response submitted.
14: Please supply any comments related to the Submitting Loads from Multiple Subregions section. (8)
No response submitted.
15: Please supply any comments from the Load Aggregation/Disaggregation section. (9)
No response submitted.
16: Please supply any comments related to the LOLE Study Load Forecast and Load Growth Rate section. (10)
No response submitted.
17: Please supply any comments related to the Appendices.
No response submitted.
General Comment