01: Please supply any comments related to the Introduction or Definitions sections. (1)
Concerning ‘Customer Contracted Load’: WRAP Participants participate at the LRE level, not necessarily the BAA level.
Concerning the term ‘Super Peak’: ‘Super Peak’ is already a common industry term for a type of energy product. Using a different term is recommended in this BPM, such as ‘Core Winter Months’ or ‘Winter Peak Months’.
02: Please supply any comments on the Demand Response Utilization section. (2)
PacifiCorp will look forward to submitting a program change request, once opened, to add an additional Demand Response category as was contemplated on page 73 (1st paragraph) of the WRAP Design Document but which was not included in BPM 105.
Please elaborate further on the effects of registering a Demand Response resource in category two versus category three. From the description, resources in category two are not subtracted from the monthly P50 load before the PRM is applied, whereas resources in category three are. Are resources in category two factored into the Operations Program sharing calculation, and resources in category three are not? Please provide more information in the BPM, as this will help guide decision making.
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)
Per this BPM there is no provision that requires Participants to include known new loads that were not reflected in the monthly P50 load forecast provided by the PO. Additionally, there is no penalty mechanism for entities whose actual loads far exceed the monthly P50. This creates an avenue for Participants to lean on the program until actual loads become incorporated into the Participant’s P50 calculation, which will take several operating seasons.
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)
The 5% threshold for an alternative load forecast should be removed. If a Participant can acceptably demonstrate an alternative load forecast to the Program Operator, it should be able to be utilized. The 5% threshold can impose significant financial consequences to Participants, and potentially expose the WRAP to increased RA risk.
For a Participant with a large load footprint, the forward procurement costs associated with just 1% of P50 can result in several million dollars of additional net power costs to that Participant’s customers.
For example, if a Participant’s internal forecast results in a P50 of 9,500 for July, while WRAP forecasts a P50 of 9,785MW for July, which has a PRM of 15%. 9,500 is not more than 5% different than 9,785, so WRAP will hold the Participant to the 9,785 P50 value, resulting in the Participant needing to provide (or procure) an additional 328MW than necessary. 285MW additional load + 15% PRM = 328MW additional capacity requirement for July.
Conversely, a Participant whose internal P50 load forecast exceeds the value provided by the PO by less than 5% can potentially lean on the program and be within bounds of this BPM.
While PacifiCorp believes WRAP Participants to be acting in good faith, a Participant whose internal load forecast exceeds the monthly P50 provided by the PO, regardless of by how much, is incentivized to not report that information.
As an additional note, please include the form referenced in this section within the BPM itself for review. The form itself may impose requirements not subject to a review process.
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)
PacifiCorp would appreciate additional language in this section on how these loads are combined to reach a total P50 load forecast. PacifiCorp is of the view that loads in two subregions should be combined on a coincident peak basis for use in the P50 peak calculations, as opposed to a summation of two non-coincident peaks. For example, if load in one subregion peaks on July 10th, and load in the other subregion peaks on July 13th, while the coincident peak of both loads occurred on July 12th, the coincident July 12th peak value should be used for modeling purposes.
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