COMMENT FOR BPM 105 - Qualifying Resources

Submitted July 18, 2023, 4:29 p.m.





01 Please supply any comments related to the Introduction, Definitions, or Background sections.

 No comment at this time.

02 Please supply any comments related to the Resource Registration – Resource Eligibility and Timelines section.

 No comment at this time.

03 Please supply any comments related to the Resource Registration – Late Registration of Resources section.

 No comment at this time.

04 Please supply any comments related to the Resource Registration – Qualifying Resource Aggregation section.

 No comment at this time.

05 Please supply any comments related to the Resource Registration – Generator Testing section.

 No comment at this time.

06 Please supply any comments related to the Resource Registration – Operational Testing section.

It is the understanding of SRP that jointly owned resources, outage data, and testing are the responsibility of the plant operator. SRP encourages the WPP to clarify the need for rules for jointly owned resources to be explicitly defined in the BPM.

07 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.

 No comment at this time.

08 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.

 No comment at this time.

09 Please supply any comments related to the Resource Registration – Provision of Test Reports in the FS Submittal section.

 No comment at this time.

10 Please supply any comments related to the Resource Registration – Testing for Late Registered Resources section.

 No comment at this time.

11 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Background section.

 No comment at this time.

12 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Qualified Resources Included in FS Submittal That Have No QCC Previously Calculated section.

 No comment at this time.

13 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Thermal Resources section.

 No comment at this time.

14 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Variable Energy Resources section.

SRP encourages the WPP to specifically define the engineering data required by plant operators of wind and solar resources that do not have historcal output and whether participants can provide synthesized output under historical conditions.

Additionally, SRP recommends for the Variable Energy Resource (VER) Effective Load Carrying Capability (ELCC) study process, the Loss of Load Expectation (LOLE) benchmark metric used in the ELCC accreditation study be a one day in 10-year threshold.

15 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Energy Storage section.

 No comment at this time.

16 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hybrid Facilities section.

 No comment at this time.

17 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Demand Response section.

 No comment at this time.

18 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hydro Resources section.

 No comment at this time.

19 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Other Resources section.

 No comment at this time.

20 Please supply any comments related to Appendix A.

 No comment at this time.

General Comment

 No comment at this time.