01. Please supply any comments on the draft Task Force Schedule found in Figure 3
As WRAP Participants gain more experience from multiple non-binding seasons, it has become clear that the volatile nature of the monthly Planning Reserve Margins has created challenges for entities to anticipate the program requirements for the purposes of their resource plans. Further, many (if not most) Participants need to begin their resource planning processes before the PRMs for the planning period have been finalized. As such, Powerex would recommend that the PRC consider swapping topic 02: Earlier FS Metric/Monthly Volatility, and topic 05: Load Growth Factor, such that Topic 02: Earlier FS Metrics can be addressed earlier in the work schedule. We would note that we still see the Load Growth Factor as an important topic. However, based on conversations with other participants, it seems that looking into the stabilization of the PRMs merits being moved ahead in the work plan.
02. Please supply any comments on Concepts that could impact a commitment to go Binding or remaining in the WRAP
No response submitted.
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
No response submitted.
06. Please supply any comments on Section 3. Detailed Level of Effort Review
Powerex participated in the PRC prioritization discussion and very much appreciates the efforts by WPP to conduct the review and develop the work plan.
07. Please supply any comments on Section 4. Proposed Schedule and Plan of Action
With the recent progress being made in the two Day Ahead Market initiatives (EDAM and Markets+), it seems highly likely that the WPP and WRAP membership may soon have to focus significant effort on the integration of the WRAP program into the new market paradigms. The market designs will represent both a substantial change to the way trading and scheduling occur, as well as a potential opportunity to further improve upon the WRAP by availing the program to the dispatch and delivery optimization enhancements that the market designs will bring. As such, Powerex feels that the PRC has appropriately prioritized topic 01: DAM Optimization to begin this year, as progress on Topic 1 will provide Participants valuable details in the coming months. But further to that, given that the development of the specific market design details may come rapidly and soon, other PRC Workplan topics may be identified during this year that could require workstreams to be created and prioritized over those identified in the draft workplan schedule. With that in mind, Powerex would encourage the PRC to be ready to modify the proposed workplan, if required, to ensure that the focus of the WPP and the Participants can be put on the integration of the WRAP into the new market designs.
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