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

The inherent variability of demand response products makes estimating capacity contribution challenging without introducing significant complexity and burden to program participants. Given this challenge, the Task Force’s proposal provides a reasonable balance of risk and rigor and is well positioned to effectively estimate the capacity contribution of DR products. BPA is supportive of the proposal as offered.

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

BPA believes WPP should monitor performance to ensure testing requirements accurately reflect the performance of participating resources. Specifically BPA believes that the capability testing duration (1 hour) for DR resources with weekly or monthly dispatch limits may not provide sufficient certainty of performance. BPA would suggest monitoring the performance of those resources and increasing capability testing duration if actual performance fails to meet estimated values. This is an area of potential improvement going forward, and not reflective of a critical concern that warrants revisions to the Task Force’s proposal.

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

BPA believes that the DR QCC workbook should incorporate the simultaneous calculation of daily and hourly fatigue. Many DR products will experience a loss of capacity over multiple hours of use and multiple days of use. Calculating both factors will more accurately reflect the real-world performance of DR products and lead to more accurate QCC values. This is an area of potential improvement going forward, and not reflective of a critical concern that warrants revision to the Task Force’s proposal.

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

BPA is supportive of the redlines to BPM 105 as drafted.

General Comment

BPA appreciates the willingness of the WPP team to develop a robust workbook to predict the capacity impact of a DR resource based on program participant provided parameters. This approach will allow a diversity of demand side products to effectively participate in the WRAP without the need to create an inclusive directory of products and characteristics and will avoid unreasonable testing burden for program participants and their customers.