01: Please supply any comments related to the Introduction or Definitions sections. (1)
The definition for Contingency Reserve Adjustment – Load indicates that it is an adjustment and the definition for Contingence Reserve Adjustment – Generation speaks to a difference between two values, where the definition for load just says it accounts for Contingency Reserve purchases and sales but not against the level assumed in the LOLE study, APS thinks it is also an adjustment from the LOLE study and the definition should represent that.
Customer Contracted Load having the “Participants BAA” in the definition is confusing since the LRE is the compliance responsible entity in WRAP and does not represent the loads of any single BAA. A better way to define this is probably to say a load that the entity is the load responsible entity for but does not do the resource adequacy planning for (regardless of reason or BAA of the load).
02: Please supply any comments on the Demand Response Utilization section. (2)
The proposed Load Modifier Demand Response utilization undermines the reliability of the WRAP program by allowing for Demand Response techniques that increase the accreditation of the resource beyond the resource’s contribution to reliability. The load modifier option for accreditation of demand response takes the QCC for Demand Response and reduces the load by that amount in advance of applying the PRM when calculating the Forward Showing Capacity Requirement. The result is effectively counting the DR resource for an amount of capacity greater than its dispatchable volume by the PRM %. For example, a 50 MW DR resource with a 20% PRM would be effectively accredited 60 MW (50MW * 1.20). The result is that the WRAP footprint is 10 MW less than the 1 in 10 seasonal LOLE – and then that is compounded by any other participants using the same treatment.
California ISO directly associates a similar PRM treatment adder as a contributing factor to the blackout in 2020 (California’s treatment added the PRM vs. WRAP proposal to reduce load, but ultimately results in the same outcome.
The ISO and Energy Division have also raised this issue for consideration in the CPUC’s resource adequacy Track 4 proceeding (R.19-11-009).6 The capacity reflected by the planning reserve margin adder cannot be utilized by the ISO, yet counts as supply towards reducing system resource adequacy obligations. DMM supports the ISO’s recommendation that the planning reserve margin adder associated with utility demand response not be credited for reducing resource adequacy requirements.[1]
CAISO continued its advocation in each subsequent report and further expanded upon it’s preference at the CPUC as quoted,
“Including a PRM adder wrongly assumes curtailable load does not exist on the system and does not need to be served in the first instance, i.e., essentially treating it like “energy efficiency.” The CAISO forecasts and plans to serve all load in the operational timeframe, even load that may be curtailed if dispatched as demand response. Likewise, the load-serving entity must procure and schedule the load that a demand response provider may curtail if economic to do so or if no emergency is called, which is the case with BIP. In other words, the load that may be curtailed must be served by the load-serving entity and CAISO (which also must procure operating reserves) in the first instance for the supply-side DR resource to be curtailed.[2]”
The CPUC eventually lowered the Demand Response accreditation to mirror its contribution towards reliability starting in 2024[3].
WRAP should review Demand Response holistically as reliability in the program is weakened by the load modifier proposal. The proposed Load Modifier approach may have merit as it relates only to incremental demand response that is intended to be included as a load reduction in the future. Once the DR has been incorporated into a season, it would no longer qualify for this treatment.
Propose adding language:
“Participants that do not plan to remove Demand Response from historically deployed load but have not yet gone through the respective season with an incremental or new Demand Response program may utilize the capabilities of the Demand Response program as a Monthly P50 load modifier. This treatment is only eligible for the incremental portion of the Demand Response program or new programs that have not gone through the respective season. Utilization of a program as a Load Modifier will require the same registration, Capability Testing, and Operationally Testing requirements required of Demand Response used as a Qualifying Resources (see BPM 105 Qualifying Resources)”
Absent changes, the program should consider additional capacity requirements elsewhere in the program to make up the deficiency from the 1 in 10 LOLE standard created by this approach.
[1] Source: Feb 25,2021 CAISO Report on Demand Response Issues and Performance.
[2] https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M362/K898/362898648.PDF
[3] https://www.caiso.com/Documents/Demand-Response-Report-2023-Mar-6-2024.pdf
03: Please supply any comments on the FS Capacity Requirement section. (3)
APS would support the removal of the Demand Response Load Modifier in the equation for FS Capacity Requirement Unadjusted as discussed in response to prompt and Section #2.
04: Please Supply any comments on the P50 Peak Load Forecast section. (4)
No additional comments at this time.
05: Please Supply any comments on the P50 Peak Load Forecast - Winter P50 Peak Load Forecast section. (4.1)
The text in 6. Says the load growth factor is only applied to step 5, APS believes it should say that it is applied to steps 1 through 5.
06: Please Supply any comments on the P50 Peak Load Forecast - Summer P50 Peak Load Forecast section. (4.2)
The text in 3.2. should refer to step 3.1 and the text in 3.3 should refer to step 3.1 and 3.2. The first sentence in step 4 should refer to step 3.2 and step 2. The text should also say the output. The text in in 6 should say the Load Growth Factor will then be applied to the results of steps 1 through 5.
07: Please supply any comments on the Load Growth Factor section. (5)
APS believes the numbering in this section’s text should be Section 4.1 and 4.2 step 5.
08: Please supply any comments on the Load Growth Factor - Established Growth Rate section. (5.1)
Is there further information on how the 1.1% rate was set that should be captured in the BPM?
09: Please supply any comments on the Load Growth Factor - Participant Alternative Growth Rate section. (5.2)
APS feels that it would be best to specify up front in the section that proposed changes should only be submitted if load differs by at least plus or minus 5%. APS also would highlight there is a natural incentive for entities that have lower than 1.1% growth rates to pursue an alternative growth rate. While entities with above 1.1% are disincentivized because of the lower resource requirement calculated when using 1.1%. How does the program maintain RA if entities with lower growth rates “drop out” from the higher resource requirement? Alternatively, if the growth rate of other participants is revised whenever a participant switches to an alternative rate, will entities have enough time to procure the necessary resources to avoid penalties? This rate needs to be fairly steady, as resource procurements occur over multi-year periods.
10: Please supply any comments on the Contingency Reserves Adjustment section. (6)
No additional comments at this time.
11: Please supply any comments related to the Contingency Reserves Adjustment - Contingency Reserve Adjustment-Generation section. (6.1)
No additional comments at this time.
12: Please supply any comments related to the Contingency Reserves Adjustment - Contingency Reserve Adjustment-Load section. (6.2)
No additional comments at this time.
13: Please supply any comments related to the Excluding Load section. (7)
If load is excluded from the FS, how is that load treated during the Operations Program, if the details are covered in another BPM can we note such BPM in this section? If the load is excluded and there is a shortfall does that mean that that load is subject to curtailment?
14: Please supply any comments related to the Submitting Loads from Multiple Subregions section. (8)
Should this say Sections 2 through 7 or is there a different way that Demand Response should be handled by Participants submitting loads from multiple subregions?
15: Please supply any comments from the Load Aggregation/Disaggregation section. (9)
APS would like to better understand how a load transfer can be performed if a Participant has load in another Participant’s BAA and contracts with the host BAA’s LRE for load service of capacity and energy. The LRE is technically responsible for the load in the other BAA from a planning perspective, but the operational load service obligations are transferred contractually to the other Participant. This is a different concept then Contracted Customer Load who is inside the Participant’s BAA, but the Participant is not required to plan for their loads.
16: Please supply any comments related to the LOLE Study Load Forecast and Load Growth Rate section. (10)
If there is a change to a Participant’s growth rate through Section 5.2, is there a change to the growth rate in the LOLE study or how does the load that is modified on one Participant’s FS Capacity Requirement get picked up by the rest of the footprint, if at all?
17: Please supply any comments related to the Appendices.
No additional comments at this time.
General Comment
No additional comments at this time.