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)
No response submitted.
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)
NLSL Group Comments on WRAP’s Draft BPM103 v0.2
The NLSL Group[1] includes discrete large loads that are expected to result in 1.5-4.5 GWs of BPA’s Total Retail Load[2] by 2028. At this time, the NLSL Group is exploring paths for these loads to be included as part of BPA’s Load Responsible Obligation (LRE) obligation as well as a potential path for having large loads act as their own LRE. In order for members of the NLSL Group and their large load customers to make a well-informed decision on WRAP participation, Western Power Pool (WPP) procedural and business practice manuals (BPM) will be required. The NLSL Group has reviewed BPM 103 v0.2, has discussed the load exclusion portion with BPA, and offers these comments.
Customer Contracted Loads (CCL):
BPM 103 v0.2 provides the following definition of a CCL:
A metered customer load located within the Participant’s Balancing Authority Area where the customer as the ultimate consumer of electricity has exercised the option to purchase capacity on its own behalf and, because of this, the Participant is not the exclusive supplier of capacity on a forward basis and does not plan for the load on a timeline consistent with the Forward Showing.
As it pertains BPM 103 - Section 7 Excluding Load – Participants with CCLs in their BAA may elect to exclude loads from WRAP. We are seeking clarification for the description of CCLs - is it the intention of the WPP to require the ultimate consumer of electricity to demonstrate that they have “exercised the option to purchase capacity” as a condition of Exclusion? As written today, it can be interpreted as a requirement for CCLs to demonstrate the purchase of capacity as a condition of Exclusion.
Operational Program
BPM 103 v0.2 provides information on load exclusion during the Forward Showing program. Will there be business practices developed that describe how excluded loads will be treated during the operational program? The attestation in Appendix B refers to reliability impacts of load exclusion – will these reliability impacts be discussed in other business practices?
Load Exclusion Decision-Making
The NLSL Group would like additional information on the decision-making process for load exclusion requests. We request more specific information regarding load exclusion determinations including what criteria will be used and how any appeal process will be conducted.
Voluntary Nature of WRAP
Due to the fact that WRAP participation is a voluntary decision, the NLSL Group would like the WPP to affirm that no WRAP Participant can require a CCL to participate in the WRAP program or unilaterally assume LRE responsibilities for purposes of WRAP.
Conclusion
The NLSL Group believes that a successful WRAP program is one of the highest priorities for the region and appreciates the work that has been accomplished to date. As mentioned earlier, the NLSL Group and their large load customers desire to make a well-informed decision on WRAP participation and look forward to additional WPP procedural and business practice development to assist with these decisions.
Submitted by Steve Kerns (Sandpiper Solutions, LLC), on behalf of the NLSL Group.
sandpiper@kernsfunk.net
[1] The NLSL Group is comprised of BPA preference customers who serve or expect to serve retail members and customers that the Northwest Power Act categorizes as “New Large Single Loads” (NLSLs). Member utilities include: Umatilla Electric Cooperative, Northern Wasco County PUD, Grant PUD, PNGC Power, Clatskanie PUD, Harney Electric Coop, Klickitat PUD, and Eugene Water and Electric Board.
[2] Slide 37, https://www.bpa.gov/-/media/Aep/power/resource-program/rp-2023-11-28-public-workshop.pdf
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