01. Please supply any comments on the draft Task Force Schedule found in Figure 3
PSE recommends establishing an arbitration process or dedicated task force to efficiently resolve matters like those outlined in 2024-CRF-014 regarding the Flexibility of Jointly-owned Resources. Rather than requiring a lengthy multi-year review cycle, many of these issues could be addressed through a streamlined process where a specialized task force reviews the matter and recommends appropriate documentation updates. This approach would not only expedite resolution of such issues but would also help manage the workplan more effectively by allowing more urgent matters to be prioritized for active consideration.
02. Please supply any comments on Concepts that could impact a commitment to go Binding or remaining in the WRAP
PSE proposes consolidating the task force items currently listed under 2024-CRF-002, 2024-CRF-005, and 2024-CRF-24 into a single comprehensive long-term workplan item, given their closely interrelated nature. This consolidation would allow for a more coordinated and efficient approach to addressing these interconnected matters.
We would like to take this opportunity to recognize the importance of developing a comprehensive regional load and resource forecasting practice to enhance long-term regional planning standards.
In order to expedite and avoid delays in getting a binding program up and running, we recommend utilizing existing historical P50 calculations without load growth adjustments, particularly as these relate to seasonal planning just three months from the cure period deadline. We propose that a task force is setup for accomplishing the long-term load and resource forecasting objectives and standards. Therefore, we recommend reclassifying these CRF items to the "Long" Time Score category. This would allow prioritizing more urgent items that directly impact compliance for the upcoming binding season, rather than focusing on longer-term planning elements at this time.
03. Please supply any comments on the Executive Summary
No response submitted.
04. Please supply any comments on Section 1. Background
No response submitted.
05. Please supply any comments on Section 2. PRC Prioritization Exercise
PSE has comments specific to each of the CRF workplan items as follows:
2024-CRF-003, DR QCC
PSE supports the development of enhanced Effective Load Carrying Capability (ELCC) calculations for Demand Response (DR) programs. Currently, participants engage in various Demand Response, Virtual Power Plant (VPP), and similar programs, making it challenging to determine WRAP eligibility. The establishment of clearer and more comprehensive guidelines would greatly assist participants in evaluating and qualifying their potential programs.
2024-CRF-004, Day Ahead Market Optimization of the Operations Program Holdback
PSE fully endorses the optimization of Western Resource Adequacy Program (WRAP) deployments through Day-Ahead (DA) and Real-Time (RT) market re-dispatch processes.
2024-CRF-010, Capability Testing Requirements for Seasonal Compliance
We recommend that both the Tariff and Business Practice Manual (BPM) explicitly clarify the permissibility of using historical data for Operations and Capability testing requirements. It is important to recognize that thermal resources in the Pacific Northwest region typically demonstrate higher capability during winter months compared to summer due to ambient temperature variations. We strongly advocate that capability testing should be based on demonstrated data and established standards, rather than relying on isolated in-person inspections conducted at arbitrary times throughout the year. If these changes primarily involve BPM or Tariff modifications, we suggest this item could be reclassified to the "Short" time category.
2024-CRF-008, CAISO High-Priority Wheeling Through in WRAP
We support efforts to resolve ambiguities and to clearly identify acceptable transmission categories for both WRAP forward showing and operational requirements. Specifically, we advocate for explicit clarification regarding all wheel-through and wheel-out transmission and products, including the California Independent System Operator (CAISO) High-Priority Wheel-through transmission and generation Wheel-out e-tags such as the CAISO Generation-Firm Provisional (GF-P).
06. Please supply any comments on Section 3. Detailed Level of Effort Review
No response submitted.
07. Please supply any comments on Section 4. Proposed Schedule and Plan of Action
No response submitted.
08. Please supply any comments on Section 6. Next Steps
No response submitted.
09. Please supply any comments on Appendix A - Change Request Form Compilation
No response submitted.
10. Please supply any comments on Appendix B - PRC Minutes Dec. 18th, 2024
No response submitted.
11. Please supply any comments on Appendix C - PRC Minutes Jan. 23rd, 2025
No response submitted.
12. Please supply any comments on Appendix D - PRC Minutes Feb. 19th, 2025
No response submitted.
General Comment