01 Please supply any comments related to the Introduction, Definitions, or Background sections.
In Background, spell out first instance of PO.
In Background, clarify if there is a Form that has to be completed (please reference this form on the WPP website) in addition to submitting data through the Advance Assessment workbook. Clarify if this section is referring to BPM 101.
02 Please supply any comments related to the Resource Registration – Resource Eligibility and Timelines section.
Please outline the process and timelines clearly (For example, what is the duration and frequency of the advance assessment?) What are some considerations to shorten these timelines? How does this align with Section 14.3 in the Tariff?
Please list out all outcomes of not meeting resource registration deadline, up to and including the usage of discounted QCC
Clearly specify if the Advanced Assessment establishes all or some of QCC, PRM, LOLE, and how the registration/advanced assessment deadlines align with PRM determination as defined in the Tariff section 14.3. See the table below for a sample of timelines based on the Tariff. In this example below, the advance assessment deadline for Summer 2026 is after the deadline for the PO to issue the recommended PRM.
Advance Assessment deadline from BPM 105: Summer 1/31/2025, Winter 1/31/2025
Tariff Recommended PRM: Summer 11/1/2024, Winter 4/1/2025
Tariff Final PRM: Summer 2/1/2025, Winter 7/1/2025
Tariff FS deadline: Summer 11/1/2025, Winter 4/1/2026
Example season begins: Summer 6/1/2026, Winter 11/1/2026
For “Resources owned and operated by entities that are not Participant”, instead of 'resources ... must be registered' specify who will register resource.
In Tables 1 and 3, explain why are PPAs with another participant excluded from listing the contracted percentage?
03 Please supply any comments related to the Resource Registration – Late Registration of Resources section.
For the Ownership Percentage, why is there a difference in treatment between "Contracts" and "Resources"?
04 Please supply any comments related to the Resource Registration – Qualifying Resource Aggregation section.
No response submitted.
05 Please supply any comments related to the Resource Registration – Generator Testing section.
In this section it would be helpful to describe why there is a need for two different tests and the usefulness of each in the program design. Do the Operational test or the Capability test limit the PO modeled QCC? If so, clearly specify how they limit (For ex., Final accredited capacity = Minimum (PO modeled QCC, Capability Test / Operational Test MW)
MOD-025 test based capacity is influenced by the temperature on the day that the testing occurred. For thermal resources, there can be significant differences in capability as a function of ambient temperature derates. As a result, utilizing MOD-025 tests which are conducted on random days of a year for establishing capability will lead to very inconsistent Thermal capability used for establishing LOLE/PRM for the footprint. It will also make it challenging for participants with significant Thermal resources to claim their full Thermal Capacity values for the purposes of meeting their forward showing requirements.
This section presumes that MOD-025 is the appropriate method for establishing Thermal capability and that it is acceptable to perform these tests multiple times a year. Our discussions with plant engineers indicates that there is a reason this test is conducted once in five years, as the testing process results in numerous unit trips. Given that many participants have their resources in organized markets, it is either infeasible or very uneconomical to introduce the risk of unit tripping and the burdens of additional MOD-025 tests (one for the Winter and one for the Summer).
The feedback we get from our plant engineers is that MOD 32 is the proper test for thermal capacity calculation as it is calculated based on assumed ambient temperatures. PSE appreciates a discussion (perhaps in the FS Workgroup) regarding the best practices for establishing Thermal capability before making it a part of the BPM.
Some considerations include:
- Does it make sense to establish temperature standards by zone and then determine the Thermal capability based on the established temperature standard?
- Does it make sense to establish a consistent percentile based methodology utilizing historical data ?
Is the description of the Capability Test developed by WRAP? If not, simply provide outside reference. Otherwise it looks like WRAP is prescribing/defining these requirements and enforcing penalties.
Spell out first instance of UCAP (Unforced Capacity).
06 Please supply any comments related to the Resource Registration – Operational Testing section.
Please clearly state the need for two tests - Capability and Operational and the differences and use cases for each of these tests.
Please clearly state how these test are to be performed. Is this test similar to the MOD-25 test based on NERC standards or is this a PA/PO established test. Identify use cases, duration and frequency for these tests.
For Thermal resources the documentation states “Any hour with the unit operating at or above 90% of the Net Generating Capability may be deemed a successful Operational Test.” Since thermal plants produce less in the Summer compared to Winter due to ambient temperate derating, please clarify why the thermal tests are not seasonal.
With regards to the following reference, please clarify “previous seasons”
“Test data shall be compiled and submitted via the FS Submittal process, as outlined in BMP 108 Forward Showing Submittal. The Operational Test must achieve a minimum of 90% of the highest monthly QCC value from the Participant’s current and previous seasons FS Submittals.”
07 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.
No response submitted.
08 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.
No response submitted.
09 Please supply any comments related to the Resource Registration – Provision of Test Reports in the FS Submittal section.
No response submitted.
10 Please supply any comments related to the Resource Registration – Testing for Late Registered Resources section.
No response submitted.
11 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Background section.
No response submitted.
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 response submitted.
13 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Thermal Resources section.
No response submitted.
14 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Variable Energy Resources section.
No response submitted.
15 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Energy Storage section.
No response submitted.
16 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hybrid Facilities section.
No response submitted.
17 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Demand Response section.
No response submitted.
18 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hydro Resources section.
The BPM should clearly define what assumptions go into the Baseline upper limit QCC calculation and also clearly define what, if any, assumptions are allowed for alternative lowered QCC values.
The BPM should state what, if any, maintenance outage assumptions are to be used for Advance assessment compared to the maintenance outages used for the FS program. Should the advanced assessment (given the two plus years planning timeline) use outage assumptions based on historical actual unforced outages instead of “planned outages” for the forthcoming FS season?
Please specify exactly what result data is provided to the program operator (PO). Is it simply a screenshot of the QCC values or is it all the input data, assumptions and model workbooks?
For MidC projects, Buyer has to review assumptions, validate results, get JCAFs signed and model QCC in the FS workbook. Please establish clear deadlines for the Seller (MidC operators) to provide draft QCC results and final QCC results prior to the FS deadlines consistent with the dissemination of QCC data by the PO for all the other non-hydro resources. This BPM should also clearly state what elements of the model workbook and assumptions have to be provided by the Seller to the Buyer for validation purposes, JCAF signing and FS modeling. For example, the BPM should clearly state that the Seller should provide both the baseline QCC (maximum allowed by the program) as well as the QCC that the Seller may be modeling for their own internal risk management purposes.
Per the tariff, 'If ten years of historic data is not available for the Storage Hydro Qualifying Resource, the Participant may alternatively employ data on the same metrics from a demonstrably comparable facility or apply another method that provides reasonable confidence in the reliability of the predicted values, as more fully set forth in the Business Practice Manuals.' We did not see these metrics clearly set forth in this BPM.
19 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Other Resources section.
No response submitted.
20 Please supply any comments related to Appendix A.
No response submitted.
General Comment
Please include section numbers throughout the document.
These capitalized terms are not defined in the tariff or BPM105 (there are probably more, here is a sample):
- WPP Data Instruction Manual
- Data Instruction Manual
- Max Capacity (In Table 1, ESR section)
- Advanced Assessment Data Request
- Hydro QCC Workbook
- Cascaded Dual Plant