01: Please supply any comments related to the Introduction or Definitions sections. (1)

• Contingency Reserve Adjustment: Suggest revising the Contingency Reserve Adjustment to the following: Contingency Reserve Adjustment: An adjustment to the FS Capacity Requirement to account for changes in Contingency Reserve requirements resulting from a Participant’s contractual purchases and sales, which include the Contingency Reserve as a specific part of the contract. The Contingency Reserves have two components, and the Contingency Reserve Adjustment could impact either of both components: Generation and Load. This adjustment can be positive or negative in direction based on contract direction: purchase or sale.

 

• Customer Contracted Load: Suggest revising the Customer Contracted Load definition to the following: A metered customer load (specifically metered) located within the Participant LRE’s Service Territory where the customer as the ultimate consumer of electricity has exercised the option to be fully responsible for all  purchase capacity and energy on its own behalf and, because of this, the Participant is not the exclusive supplier of capacity on a forward basis and therefore does not plan for the load on a timeline consistent with the Forward Showing.
  • Specifically, the Customer Contracted Load definition should use the term Service Territory rather than Balancing Authority Area

 

• Demand Response Load Modifier:  The purpose and/or use of the load modifier option is unclear, and we suggest it be removed. Since the load modifier option clearly states “will require the same registration, Capability Testing, and Operational Testing requirements as required of Demand Response used as a Qualifying Resource” – why are we giving an option of load modifier if a participant already has to do all steps required to get a QCC (option 2) and is required to submit them in some fashion to prove the load modifier is accurate.  We are not clear on how the program would call on a ‘Load Modifier’ and how this just doesn’t result in a participant that is using the modifier always having a load forecast that is greater then expected in the OPS program.

 

• Forward Showing (FS) Capacity Requirement Unadjusted: Suggest revising this definition to the following: The FS Capacity Requirement Unadjusted takes into account Demand Response used to reduce monthly P50 Peak Load Forecast embedded in the historic load data set and the monthly FSPRM. The FS Capacity Requirement Unadjusted does not take into account the Contingency Reserve Adjustment. 

 

• Super Peak Months: The name “Super Peak Months” needs to be changed. Super Peak is a regularly used term that does not represent Dec, Jan, Feb. This will cause confusion.

02: Please supply any comments on the Demand Response Utilization section. (2)

Suggest deleting Option 3, Load Modifier. The purpose and/or use of the load modifier option is unclear.  It is not clear how the program would call on a ‘Load Modifier’ and ensure the use of the Load Modifier option in the Forward Showing to simply reduce the P50 peak load doesn’t result in the participant always having a load forecast that is greater than expected in the OPS program.  The load modifier option clearly states that this option “will require the same registration, Capability Testing, and Operational Testing requirements as required of Demand Response used as a Qualifying Resource”. Why are we giving an option of load modifier if a participant already must do all steps required to get a QCC (option 2) and is required to submit in some fashion to prove the load modifier is accurate, why not account for it as a resource with the calculated QCC value?

03: Please supply any comments on the FS Capacity Requirement section. (3)

• The equation should be adjusted to reflect that the CR adjustment could be in either direction.
• Remove the ability to use the Demand Response Modifier

04: Please Supply any comments on the P50 Peak Load Forecast section. (4)

• Winter P50 Peak Load Forecast: While the Super Peak months (name needs to be changed) balances three months across the winter well, can we show how the methodology can account for all load peaking at the same time (e.g. MLK weekend or June heat dome)?

05: Please Supply any comments on the P50 Peak Load Forecast - Winter P50 Peak Load Forecast section. (4.1)

• Section 4.1 states “An example spreadsheet showing steps 1 through 4 is posted on the WPP website.” Please provide location on WPP Website of example files (not sure if a location exists yet for these referenced examples, but general location on website should be referenced).

06: Please Supply any comments on the P50 Peak Load Forecast - Summer P50 Peak Load Forecast section. (4.2)

• Please review step numbers and references for accuracy
• Please provide location on WPP Website of example files (not sure if a location exists yet for these referenced examples, but general location on website should be referenced).

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)

Suggest revising 5.1 to the following: A WRAP-wide established load growth rate (or set of established growth rates) could potentially account for location, weather, Participant type, Participant customer composition (balance between retail, commercial, and industrial). The established growth rate is currently set at 1.1%. Changes to the established growth rate for the

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)

• Please adjust the ending of section six to identify that adjustment can be bidirectional: The FS Capacity Requirements Unadjusted are therefore adjusted for a Participant’s Contingency Reserve requirements (plus or minus). A Participant’s Contingency Reserve Adjustment has two components: Contingency Reserve Adjustment-Generation and Contingency Reserve Adjustment-Load.

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)

• WRAP is not a BA level program, replace “BAA” with “Service Territory”

 

• Is this section trying to say that a Participant with loads outside its Primary BAA could exclude those loads from WRAP? As an example, BPA could exclude any and all load that is outside of BPAT? Fundamentally, that would be a BA based resource adequacy approach that each BA is responsible for the RA of all loads inside the BA (and nothing outside).  WRAP was developed as a LRE program. This seems to fundamentally break the Resources Adequacy model that was chosen for WRAP. Section 8 specifically goes into multiple sub regions. Sub regions by nature would encompass disparate BAs.

14: Please supply any comments related to the Submitting Loads from Multiple Subregions section. (8)

• Bonneville suggests that this section be re written so that is clearly articulates the following: 1) How a single workbook can be used (with all requirements of loads and transmission), and 2) clearly identify any and all additional requirements that the participant has to use the lower FSPRM factor.

15: Please supply any comments from the Load Aggregation/Disaggregation section. (9)

• The purpose of Section 9 is hard to understand.   We believe this is referencing a situation where a single LRE has two different disparate loads served by different resources within a single sub region Suggest adding additional detail to make this very clear to a reader.

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.

• Appendix A:
  • The sample attestation language is missing a table to house the pertinent details that the attestation must present in order to be accepted.
  • Documents participant attaches to attestation should include specific details and values to support the load forecast modifications. 
  • Details should be submitted in a format that allows a cover page to be shared publicly, and non-public information clearly marked as confidential.
  • Program administrator should be making public notice, at least to other participants, of a non-standard modification being made, without releasing any confidential information.

 

• Appendix B:
  • Appendix B is missing at least one layer of Attestation, 1) the customer whose load is being excluded should be signing the Attestation along with the Senior Official of the Participating LRE.  2) BPA proposes that the Attestation should also include acknowledgement from a senior official of the BA in which the load resides that the BA is aware of the load exclusion from WRAP.
  • This attestation should include documentation demonstrating how it can be proven in the OPS program timeframe (and after the fact tests) that the load in question was excluded from the LRE’s OPS time frame submittal: how the load is specified, and how it is metered separately from the LRE’s other loads.
  • Similar to Appendix A, this submittal should include a summary for public release and have confidential materials clearly marked. The Program Administrator should presumptively accept all submitted load exclusions that meet the required documentation. However, there should also be a public notice of all load exclusion, or at a minimum to all other participants in the sub region, as this shows load within the participant’s footprint that does not have RA planning at the same levels as other loads participating in WRAP.  Notice of all load exclusions is important because load exclusions can create additional risk for other participants.

General Comment

Bonneville appreciates the opportunity to comment on this BPM