01 Please supply any comments related to the Introduction, Definitions, or Background sections.

No response submitted.

02 Please supply any comments related to the Resource Registration – Resource Eligibility and Timelines section.

• Powerex suggests that a table be included in this section, specifying all of the critical due dates for the Forward Showing data submission. The dates would be relative to the start of the Summer or Winter binding seasons.
• Page 4: “The registration process for all Qualifying Resources, other than Storage Hydro Qualifying Resources, will require, but will not be limited to, the items set forth in Table 1, Table 2, and Table 3...”
• Powerex believes this sentence should be reworded, to be clear that Storage Hydro resources are subject to Table 2 and 3 only.
• Table 2 requires thermal resources to submit GADS data so SPP can calculate forced outage rates. However, there is no requirement for Storage Hydro resources to submit GADS data. Historically, participants have been asked to submit GADS data for Storage Hydro resources as part of the SPP Study Data Request. Powerex suggests the language be clear for the requirement of Storage Hydro resources in providing their GADS outage data.

03 Please supply any comments related to the Resource Registration – Late Registration of Resources section.

Powerex notes that utilizing a class average for Storage Hydro resources is problematic and would be difficult to apply in practice. Different hydrological conditions, reservoir limitations and size, and non-power constraints will vary by project. We suggest that for Storage Hydro resources, given their unique nature, the Participant can propose a methodology consistent with the Storage Hydro methodology for calculating the QCC of the resource. The modelling approach will be reviewed and approved by the Program Administrator. If the proposed methodology is approved, the Program Administrator can accept the late registration of a Storage Hydro Resource. For example, a new project downstream of an existing Storage Hydro project could utilize the QCC results of the existing project, adjusted proportionally up or down to the nameplate capacity of the new project.

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.

Powerex would suggest this section clarifies that only thermal resources utilizing the Equivalent Forced Outage Factor methodology are subject to providing a capability test. If a thermal resource is not dispatchable by the participant, but the participant is required to take 100% of the output of that resource, the QCC could be determined by another method utilizing the average output in Capacity Critical Hours. In this case, the resource would not need to provide a capability test.  

06 Please supply any comments related to the Resource Registration – Operational Testing section.

Powerex would like to understand why the Operational Test for Storage Hydro resources must achieve a minimum of 90% of the highest monthly QCC value from the Participant’s current and previous seasons FS submittal. Powerex believes that the monthly QCC numbers the Operational Test is performed against should apply to the Forward Showing being completed.

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.

Powerex believes that for newly installed Storage Hydro units, the term “design output” might not be specific enough to assess the QCC with. We suggest that for new Storage Hydro resources, given their unique nature, the Participant can propose a methodology consistent with the Storage Hydro methodology for calculating the QCC of the new resource. The modelling approach will be reviewed and approved by the Program Administrator. If the proposed methodology is approved, the Program Administrator can accept the registration of a new Resource prior to COD. For example, a new project downstream of an existing Storage Hydro project could utilize the QCC results of the existing project, adjusted proportionally up or down to the nameplate capacity of the new project.

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.

Powerex notes that the Operational Test for Energy Storage Resources is missing details on what constitutes a successful test.

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.

Powerex suggests that for new Run of River (RoR) Resources with less than three years of historical generation data, simulated generation data based on historical inflows could be provided in the Advanced Assessment and used to determine the QCC. When at least three years of generation data is available, the QCC could be determined without the use of simulated data, instead using the historical generation output in Capacity Critical Hours starting when the Resource reached COD.

19 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Other Resources section.

Powerex suggests an alternate name for the section titled “Public Utility Regulatory Policies Act (PURPA) Qualifying Facility Resources”. The discussed method of determining QCC should be available for any resources that either (i) are not dispatchable; or (ii) require the purchaser of energy from the resource to take energy as available from such resource. The name for these resources could instead be “Non-Dispatchable, Must Take Resources”, to be inclusive to participants like Powerex that are not subject to PURPA legislation, but meet the above stated criteria.  PURPA Facilities could be used as an example in the section but not limited to. Furthermore, an Operational Test should be defined for resources that choose to qualify with this method.

20 Please supply any comments related to Appendix A.

Powerex thinks that Appendix A should address Resources that have not yet reached Commercial Operational Date (COD). We believe that the Program Administrator will review and approve a methodology for those new resources. Our suggestion is that Appendix A mentions this scenario.

CODs are set by many varying factors and influences. Given the importance of the COD, Powerex would suggest that the WPP should consider adding more clarity with respect to how CODs should be set for the purposes of the WRAP, as well as clarity how a change to a COD may impact both the Forward Showing and Operational aspects of the program.

General Comment

Powerex would like to highlight the usage of the terms “unit”, “plant”, and “resource” throughout the BPM. While some aspects of the Forward Showing do involve unit level data, a Resource under WRAP is accredited QCC at the plant level. The choice of wording should be clear when a requirement is for a plant versus a unit.

Powerex also cautions on using defined terms in the BPM with capitalization, unless that term is included in the Definitions section of the BPM, or in the Tarriff. An example would be the term "Historical Outage Evaluation Equivalent" being used in Appendix A, but no other mention of what that defined term is. If no definition is necessary, then Powerex suggests removing the capitalization from the term.

Powerex also believes the BPM would benefit from having section headers and numbering, along with a Table of Contents. This would help participants navigate the BPM and be able to find relevant sections as needed.