01: Please supply any comments related to the Introduction or Definitions sections. (1)
AWEC appreciates the opportunity to provide comments on BPM 103. Related to the definitions section, AWEC is concerned that the definition of “customer contracted load” is vague and ambiguous as drafted. It is AWEC’s understanding that the intent of the load exclusion provision is to place the risk of a capacity shortage on the excluded load, as opposed to WRAP. However, the language as drafted could be read to require, as a condition of load exclusion, that consumer loads must actually purchase capacity on their own behalf as a condition of load exclusion from WRAP. This would be an additional requirement, which is beyond our understanding of the intent of the provision and raises additional concerns given the voluntary nature of the WRAP, and would effectively nullify the purpose of load exclusion since the excluded load would still need to demonstrate its capacity position. Consumers sophisticated enough to pursue and consent to load exclusion should be permitted to take on the risks of such a decision.
If AWEC’s understanding of the intent of this provision is incorrect, we would like to understand the rationale for requiring excluded load to demonstrate its capacity position, including relevant tariff provisions.
In order to clarify the definition, AWEC suggests amending the definition of “Customer Contracted Load” to read as follows:
Customer Contracted Load: A metered retail load located within the LRE’s Service Territory where the customer of LRE: (a) does not purchase energy from LRE to serve the metered retail load; and (b) has exercised the option to forego the LRE planning for the metered retail load on a forward basis. For purposes of this definition, a customer and retail-end user whose load is subject to exclusion may be the same.
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)
AWEC does not believe that WPP should institute a substantive review or approval process once loads have elected to be excluded from WRAP in accordance with the attestation in Appendix B. However, the Excluding Load section lacks detail and clarity on the process that will occur at WPP, if any, related to whether there will be an approval or acknowledgment process from WPP that load has been excluded. If WPP has the discretion to preclude load from being excluded that is otherwise supported by the Appendix B attestations (as proposed to be amended by AWEC), what is that process? When and how will determinations be made? What criteria will WPP consider in making such a determination? Will there be any type of conferral or appeals process prior to or following a determination from WPP that load may or may not be excluded? Additional language clarifying the process, or lack thereof, is needed.
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.
It may be valuable for Appendix B to reflect explicit agreement between the LRE and the customer whose specific metered load is being excluded by requiring attestations from both parties. AWEC finds it valuable to discuss whether this would be valuable from a WRAP programmatic perspective or whether these issues are best addressed through contracts between the LRE and their customers. If there is value in requiring attestations with WRAP from both the LRE and its customer, we suggest the following edits to Appendix B.
Appendix B - Load Exclusion Senior Official Attestation
Participant LRE Load Exclusion Senior Official Attestation
I, the undersigned, who as [title], serves as a senior official of [Participant], hereby request that [the amount of load served in MW that the Participant LRE is seeking to exclude] be excluded from [Participant’s] P50 Load Forecast calculation. I attest that to the best of my knowledge and belief that the customer of the load for which [Participant] is seeking exclusion has been made aware of and understands the potential reliability impacts of said customer’s load being excluded from the WRAP.
Customer Load Exclusion Senior Official Attestation
I, the undersigned, who as [title], serves as a senior official of [Customer of the specified metered load], hereby acknowledge that [Participant] is seeking to exclude [the amount of load served in MW that the Participant LRE is seeking to exclude associated with Customer’s load] from [Participant’s] P50 Load Forecast calculation at [Customer’s] request. I attest that I am aware of and understand the potential reliability impacts of [Customer’s] load being excluded from the WRAP and consent to its exclusion.
General Comment
AWEC appreciates the opportunity to offer comments on BPM 103. AWEC’s membership includes large industrial end users of electricity who are served by investor-owned utilities, customers of Bonneville Power Administration (i.e. public power), and in some cases, by third-parties via direct access programs. The particular circumstances and needs of each AWEC member are unique, and for that reason, AWEC’s interest in providing these comments is to ensure that WRAP’s load exclusion provisions are clear and provide end-use customers with the ability to make cost-effective resource adequacy decisions that fit their specific business needs. In the development of these comments, AWEC discussed its impressions and concerns with BPA.