01. Please provide any comments on the proposed Demand Response (DR) Qualifying Capacity Contribution (QCC) methodology.

No response submitted.

02. Please provide any comments on the proposed DR testing requirements.

No response submitted.

03. Please provide any comments on the proposed implementation plan and feasibility.

The implementation approach is reasonable and appropriately phased with a non-binding Forward Showing prior to binding adoption.

04: Please provide any comments on the proposed redlines to BPM 105 - Qualifying Resources.

No response submitted.

General Comment

APS appreciates all the work of the task force and WPP to develop a proposal that meaningfully advances the modeling of demand response resources and the associated accreditation, along with changes to the testing requirements of these resources. In addition to the topics addressed in the proposal, APS requests that the task force consider the following:

Behind-the-Meter Generation Tied to Load: 

The Task Force should consider how to appropriately accredit demand response resource testing that is directly tied to a specific load, particularly where behind-the-meter generation is used to offset that load (e.g., a data center with co-located generation). In these cases, the demand response capability is effectively dependent on the size of the underlying load, which may be in the process of being built out over time. 

During the initial testing period, the full load may not yet be realized, creating a situation where the resource cannot demonstrate its full potential load reduction capability under the existing testing framework.  The full demand response may not be realized because the load may continue to be ramping online at the time of testing (i.e. continued ramping to and through the WRAP season.) A large load under development may only be partially energized at the time of testing, but the behind-the-meter generation is capable of fully offsetting the ultimate build-out load. 

If the demand response resource is able to demonstrate that it can fully offset the existing load at the time of testing, it should be eligible to receive accreditation up to the full expected load at build-out for the applicable month/season. 

This approach would better reflect the forward-looking reliability contribution of the resource while avoiding unnecessary under-accreditation due to timing mismatches between load growth and testing requirements.  This approach is only enabled where load and DR resource ramp together - thus a shortage in DR also translates to a reduced amount of load and the load/resources are known with an ability to test a portion of the resource within the appropriate testing window.

The Task Force may consider allowing this through documented load forecasts, staged validation requirements, or conditional accreditation subject to future verification. 

Inter-Participant Load Shifting:

Certain DR configurations may shift load across participants during Capacity Critical Hours rather than reducing net system load.

Example: Data Center 1 in Participant A reduces load while Data Center 2 in Participant B increases load.

This may overstate regional capacity and create inconsistencies in accounting.

Recommendations:

- Require demonstration of net load reduction at a regional or subregional level.

- Consider limiting or adjusting QCC for cross-participant load shifting programs.

- Require disclosure or attestation regarding such practices.