01: Please supply any comments related to corrections in the Definitions Section
Central Hub: This definition should not use the term it is trying to define in the definition. Central hubs do not permit energy delivery. It is a point where energy transactions can be made. Suggested revised definition: Designated points on the transmission system in the particular sub region where WRAP transactions can be facilitated.
Demand Response Capacity Resource: BPA requests that WPP use more precise, but less restrictive, language than “utilized exclusively.” E.g. “is accounted for in,” or “is identified/designated in”. “Utilized” is too vague when resources are discussed in terms of both physical assets and numeric values. “Exclusively” introduces questions of scope.
Demand Response Load Modifier: BPA requests clarity from WPP on the following: Section 16.1.3, titled “Demand Response Load Modifier,” begins: “A Participant’s demand response or load reduction program, which must be controllable and dispatchable by the Participant or by the host utility, and which has met certain testing requirements consistent with Business Practice Manuals.”
Is this definition and section 16.1.3 consistent? If yes, should they be combined?
Also for the Demand Response Load Modifier when using the phrase “utilized exclusively”: request WPP use more precise, but less restrictive, language than “utilized exclusively.” E.g. “is accounted for in,” “is identified/designated in”. “Utilized” is too vague when resources are discussed in terms of both physical assets and numeric values. “Exclusively” introduces questions of scope.
Holdback Capacity: BPA found this definition confusingly and similar to definition for “Voluntary Holdback”. Request that WPP make a clearer distinction between these two terms.
System Sale: “Fleet” seems out of place. Is it here to clarify that the capacity/energy is coming from generation resources owned by one of the parties as opposed to the conveyance of rights to capacity/energy? Or, is it to replace the “two or more” language in the previous version? The Change Request Form says this definition was modified to eliminate “Qualifying Resources” to allow for purchases by participants from non-participants with unregistered resources.
Is the phrase “from a fleet of generating resources” necessary? The term is ambiguous and should be avoided unless serves a clear purpose.
Additionally, the following revision to the definition is suggested: bilateral agreement that conveys generating capacity and/or energy from a fleet of generating resources from one party to another.
Voluntary Holdback: the first sentence of this definition is confusing. Please consider revising to simplify it. Also, suggest moving the last sentence of this definition to section 19.4, it is unusual to see a requirement imbedded within a definition.
02: Please supply any comments on redlines to Tariff section 7 (Credit Requirements and Settlement for Holdback and Delivered Energy)
7.2: Final statements like that made in 7.2 do not need to be in the tariff. This should be high-level and point to a BPM. Does 7.2 take into account price revisions in price indexes and CAISO?
03: Please supply any comments related to redlines to Tariff section 10.2 (Treatment of Confidential or Commercially Sensitive Information)
The opening sentence of this section is long and confusing. BPA requests that WPP break it up into more easily read sentences.
BPA suggested revision for the first sentence: WPP shall identify in the Business Practice Manuals those categories of Participant-specific data and information, originating with the Participant or WPP that it will treat as confidential or commercially sensitive. WPP shall not disclose information falling into those categories publicly, to any other Participant, or to any other entity, except as provided for in this Section 10.
04: Please supply any comments related to redlines to Tariff sections 14.2.1.2, 16.1.5, and 19.2 (relating to Forward Showing Submittal demonstration of inter- subregional transmission in lieu of Capacity)
16.1.3 – Recommend that the tariff not use “program” in “A Participant’s demand response or load reduction program”. This is not a defined term and is not used elsewhere in the tariff.
Recommend using the word “applicable” rather than “certain” when discussing testing requirements.
Regarding the following sentence: “the Participant or by the host utility, and which has met certain testing requirements consistent with Business Practice Manuals…”: BPA requests that WPP clarify if “consistent” is being used to allow for testing requirements different from those in the BPMs, but still acceptable to WPP. If not, “consistent” may offer more flexibility than WPP intends.
Request for clarification: The QCC of what? The subject of the first sentence is “program”. This is the only section that uses the phrase “demand response program” or “load reduction program” and neither of those phrases are defined. Please clarify specifically what is the subject of the QCC calculation. Additionally, should this sentence on determining QCC be in section 16.2?
“A Demand Response Load Modifier’s QCC is subtracted from the P50 Peak Load Forecast” – BPA suggests “is” be changed to “shall be”
“…nothing prohibits a Participant from using an existing demand response or load reduction program that does not satisfy the requirements for Demand Response Capacity Resources…” Should this be in the “Advance Assessment” section? E.g. “Participants may use a demand response or load reduction program that does not satisfy the requirements of DRCR or DRLM in their advance assessment”?
In addition, DRCR has its own section: 16.2.5.4., which contains much of the same information. BPA recommends that this section just point to 16.2.5.4
05: Please supply any comments on redlines to Tariff sections 16.1.2.1, 16.1.2.3, and 16.2.5.2.2 (related to corrected "annual LOLE" references to "Seasonal LOLE")
No response submitted.
06: Please supply any comments on redlines to Tariff sections 16.1.2, 16.2.5.4, 20.1.1 (related to options for DR)
16.2.5.4 seems to convey the same information as 16.1.3, but in a more clear and concise manner. Recommend modifying section 16.1.3 to point to this section rather than restating the information.
Section 16.2.5.4 should point to where the discussed testing requirements will be articulated.
07: Please supply any comments on redlines to Tariff section 16.2.7 (relating to Total RA Transfer)
No response submitted.
08: Please supply any comments on redlines to Tariff section 16.2.8 (relating to Planned Outages)
No response submitted.
09: Please supply any comments on redlines to Tariff section 16.3.2 (relating to Transmission Exceptions)
“WPP will consider the exception category terms, conditions and limitations set forth above, and may consider…”: This language was pulled up from below the category sections and should now say “set forth below”.
“A Participant granted a transmission exception under either Section 16.3.2.1 or Section 16.3.2.2 must complete a monthly transmission exception check report…”: BPA suggests a seasonally completed transmission exemption check report. Monthly seems like an unnecessary administrative burden.
“Failure to timely submit a required monthly report will result in assessment of a Deficiency Charge…”: BPA suggests a reporting cadence of seasonally rather than monthly.
10: Please supply any comments on redlines to Tariff sections 17.2.7 and 17.2.8 (relating to Forward Showing Deficiency Charge)
No response submitted.
11: Please supply any comments on redlines to Tariff section 19.1 (relating to Operations Program Timeline and Supporting Information
Having a name that sets apart the “Operating Day” in question from all the Operating Days that precede and follow it during a time period would provide some clarity – e.g. having an “identified Operating Day” so that it is clear that there is a Preschedule Day for the identified Operating Day, but that the Preschedule Day is also its own Operating Day. While every day during the season is an Operating Day, the provisions of Section 19 as written apply to a single identified Operating Day. Performance obligations during the seven days preceding an identified Operating Day and on the identified Operating Day itself include the obligations accruing to each of the seven preceding Operating Days and the seven following Operating Days.
12: Please supply any comments on redlines to Tariff section 19.4 (relating to Operations Program Timeline and Participant Tx Inputs)
No response submitted.
13: Please supply any comments on redlines to Tariff section 19.5 and 20.4.1.2 (relating to reference correction of Subregions not containing a central transmission hub)
Rewording is needed for section 19.5 as it lacks precise and clear wording. BPA is happy to discuss further.
14: Please supply any comments on redlines to Tariff section 19.5 (relating to decription of mechanics of Voluntary Holdback)
No response submitted.
15: Please supply any comments on redlines to Tariff section 20.1.1 (relating to update to description of Sharing Calculation)
“Demand Response Load Modifier, as described in Section 16.1.3, refers to Demand Response…”: BPA requests definition clarity and consistency from WPP regarding use of the term “Demand Response”. This term is defined as a “resource” in the definitions section, and as a “program” in 16.1.3. Here it referred to simply as “Demand Response” – which is not defined anywhere.
Request that WPP identify the actor and demonstrable action in this provision that a participant did not identify in their load profile or in their FSCR submittal.
“A Demand Response Load Modifier must satisfy all testing requirements applicable to a Demand Response Capacity Resource, but is used to reduce P50 Load Forecast rather than as a Qualifying Resource;”: please confirm that this is also needed for the equation above this sentence.
“Load Forecast refers to the forecast of expected load for the subject hour for the loads for which the Participant is responsible;”: Suggest revising to: “…refers to the Participant’s forecast of expected load for the subject hour for the loads for which the Participant is responsible.”
Demand Response Capacity Resource - Request that WPP use more precise, but less restrictive, language than “utilized exclusively.” E.g. “is accounted for in,” or “is identified/designated in”. “Utilized” is too vague when resources are discussed in terms of both physical assets and numeric values. “Exclusively” introduces questions of scope.
16: Please supply any comments on redlines to Tariff section 20.1.3 (relating to removal of references to lesser priorities of Energy Deployment)
No response submitted.
17: Please supply any comments on redlines to Tariff section 20.2 (relating to description of mechanics of Holdback Requirement)
20.2.2 – BPA requests that WPP provide an example of the discussed optimization.
20.2.3 – The sentence, “As expected, conditions change over the Multi-Day-Ahead Assessment…” is unnecessary and should be removed.
18: Please supply any comments on redlines to Tariff section 20.4.1 (relating to how Energy Deployment occurs on Operation Day)
Please further define “shall be up to”. Does this refer to “equal” or “not to exceed”?
There needs to be a definition of the default state in this section.
19: Please supply any comments on redlines to Tariff section 20.4.1.2 and 21.1.4 (relating to reference corrections)
There needs to be a list of receipt points and an optimization methodology that can be referenced. Perhaps in a BPM?
20: Please supply any comments on redlines to Tariff sections 20.4.2-20.2.4 (relating to corrections to 85 & 80 minutes before the hour)
No response submitted.
21: Please supply any comments on redlines to Tariff section 20.8.1 (relating to incorrect conflation of "Raise Hand" with Voluntary Holdback)
No response submitted.
22: Please supply any comments on redlines to Tariff section 21.2.4 (relating to updating Energy Declined Settlement price to be the Applicable Real-time Index Price for the hour)
No response submitted.
23: Please supply any comments on redlines to Tariff section 21.2.5 (relating to change to Make Whole Adjustment formula)
No response submitted.
General Comment
BPA appreciates the opportunity to provide comments.
The Tariff change request document says it has been amended in sec 16.1.2, 16.2.5.4, and 20.1.1 to:
“Providing Participants with three mutually exclusive options for demand response:
1) Leave in historical load;
Or extract from historical load and either:
2) Deduct from monthly P50; or 3) use to meet FS Capacity Requirement”
This objective was not apparent from the edits of those sections – if WPP wants to convey this, they may want to state it more clearly.
Section 9 refers to section 7.2.2. There is no section 7.2.2 in the tariff.