01: Please supply any comments related to the Introduction or Definitions sections. (1)
No comments
02: Please supply any comments on the Demand Response Utilization section. (2)
No comments
03: Please supply any comments on the FS Capacity Requirement section. (3)
No comments
04: Please Supply any comments on the P50 Peak Load Forecast section. (4)
No comments
05: Please Supply any comments on the P50 Peak Load Forecast - Winter P50 Peak Load Forecast section. (4.1)
After Step 4 the BPM refers to the WPP website for an example spreadsheet. PGE suggests adding the actual weblink to the example spreadsheet in the footnote for easy access.
06: Please Supply any comments on the P50 Peak Load Forecast - Summer P50 Peak Load Forecast section. (4.2)
- Suggest considering making Step 1 of the summer method the paragraph: “Determine the peak load for each Month of the Summer Season…..”. This would be similar to the way Section 4.1 is organized.
- Correction to Step 3.2: “The Load Forecast Ratio for each Month of the Summer Season is the result of step 4.1 divided….”. This should refer to step 3.1 instead of step 4.1
- Correction to Step 3.3: “The Load Forecast Ratio (…) is the result of step 4.1 divided by the MW value identified in step 4.2”. This should refer to steps 3.1 and 3.2.
- Correction to Step 4: “Multiply (…) from step 4.3 by the result of step 3.” This should rather say “Multiply (…) from step 3.3 by the result of step 2.
- Correction to Step 4: The example calculation of 2411MW provided for September is not correct: 0.68 * 3571 = 2428MW
- Correction to Table 2: the numbers in the column “Monthly P50 Peak Load Forecasts” are not correct. For example 0.88 * 3571 = 3142 and not 3136.
- Suggest adding a footnote with a weblink to the exact location of the “example spreadsheet showing steps 1 through 5” instead of generically stating the it is posted on the WPP website.
07: Please supply any comments on the Load Growth Factor section. (5)
No comments
08: Please supply any comments on the Load Growth Factor - Established Growth Rate section. (5.1)
No comments
09: Please supply any comments on the Load Growth Factor - Participant Alternative Growth Rate section. (5.2)
Comment 1:
Regarding the paragraph: “…, the Participant will demonstrate that the alternative growth rate results in a peak load forecast 5% higher or lower than the peak load forecast calculated using the appropriate established growth rate discussed in Section 5.1.”
What is the basis for the 5% threshold? The approved FERC Tariff does not provide for an alternative peak load forecast limit.
PGE has concerns regarding the materiality of the 5% threshold because, based on the magnitude of an entity’s load in future years, the 5% can be very significant. PGE recommends removal of the 5% threshold and instead, the PO/PA require that participants submit detailed documentation to demonstrate the reasoning for their alternative load forecast. The PO/PA can reserve the right to deny if the Participant’s documentation does not support their alternative load estimate or if it is not materially different from the PO/PA provided estimate.
Comment 2:
Suggest providing a weblink for more direct access to the alternative growth rate request form.
10: Please supply any comments on the Contingency Reserves Adjustment section. (6)
No Comments
11: Please supply any comments related to the Contingency Reserves Adjustment - Contingency Reserve Adjustment-Generation section. (6.1)
No comments.
12: Please supply any comments related to the Contingency Reserves Adjustment - Contingency Reserve Adjustment-Load section. (6.2)
No comments.
13: Please supply any comments related to the Excluding Load section. (7)
No comments.
14: Please supply any comments related to the Submitting Loads from Multiple Subregions section. (8)
No comments.
15: Please supply any comments from the Load Aggregation/Disaggregation section. (9)
No comments.
16: Please supply any comments related to the LOLE Study Load Forecast and Load Growth Rate section. (10)
No comments.
17: Please supply any comments related to the Appendices.
No comments.
General Comment
PGE appreciates the opportunity to review and provide suggestions to BPM 103.