01: Please supply any comments related to the Introduction or Definitions sections. (1)

The definition for customer contracted load does not contemplate a situation where an end user of energy procures energy and capacity both from the host BAA (and WRAP Participant) and another supplier such as a competitive energy service provider.  In this case, the definition presumes that a WRAP Participant would not plan for the load consistent with the Forward Showing timeline.  The joint-ESPs believe this is an oversimplification and does not reflect nuances of contracting for customer loads where instantaneous demand is served by the load’s host BAA while defined products are provided by a competitive energy service provider. 

02: Please supply any comments on the Demand Response Utilization section. (2)

No comment. 

03: Please supply any comments on the FS Capacity Requirement section. (3)

Section 3 should address how any contingency reserve adjustments would be treated for  non-BAA LREs as these WRAP Participants do not hold contingency reserves explicitly; instead, contingency reserve requirements are maintained by the BAA in which the generation is located and with the BAA the load resides in.  

The joint-ESPs do not believe a contingency reserve adjustment to the FS capacity requirement would be warranted in this case. 

04: Please Supply any comments on the P50 Peak Load Forecast section. (4)

No comment. 

05: Please Supply any comments on the P50 Peak Load Forecast - Winter P50 Peak Load Forecast section. (4.1)

No comment. 

06: Please Supply any comments on the P50 Peak Load Forecast - Summer P50 Peak Load Forecast section. (4.2)

No comment.  

07: Please supply any comments on the Load Growth Factor section. (5)

WPP should clarify if a load growth assumption will apply to non-BAA LREs contracted loads.  The joint-ESPs maintain that competitive non-BAA LRE’s load forecast is a forward sales estimate, and as such, due to the nature of the customers served (non-residential) load growth assumptions are not applicable. 

08: Please supply any comments on the Load Growth Factor - Established Growth Rate section. (5.1)

No comment. 

09: Please supply any comments on the Load Growth Factor - Participant Alternative Growth Rate section. (5.2)

No comment. 

10: Please supply any comments on the Contingency Reserves Adjustment section. (6)

No comment. 

11: Please supply any comments related to the Contingency Reserves Adjustment - Contingency Reserve Adjustment-Generation section. (6.1)

No comment. 

12: Please supply any comments related to the Contingency Reserves Adjustment - Contingency Reserve Adjustment-Load section. (6.2)

No comment. 

13: Please supply any comments related to the Excluding Load section. (7)

BPM 103 does not consider where an LRE serves a specific amount of load to a customer whose entire load may be split between suppliers that may or may not both be WRAP LREs.  For example, how would WRAP accommodate a hypothetical 50 aMW load which has elected to procure 35 MW of energy and WRAP capacity from supplier A and 15 MW from supplier B?  In this case, supplier A is a WRAP participant and is LRE for 35MW (plus the PRM); whereas, supplier B could be LRE for 15 MW if they were a WRAP participant but also may not be a WRAP participant in another version of this question.  The joint-ESPs maintain these nuances should either be defined in BPM 103 or a separate BPM for non-BAA LRE nuances should be considered. 

If there is a required RA standard imposed by a particular jurisdiction which mirrors the WRAP program, e.g. the Oregon PUC RA program pursuant to UM2143, will load be excluded from WRAP should the load elect to meet the State RA program?  If so, would the same load exclusion process apply?   

14: Please supply any comments related to the Submitting Loads from Multiple Subregions section. (8)

No comment.  

15: Please supply any comments from the Load Aggregation/Disaggregation section. (9)

No comment.  

16: Please supply any comments related to the LOLE Study Load Forecast and Load Growth Rate section. (10)

No comment.  

17: Please supply any comments related to the Appendices.

Appendix B states “…the load for which [Participation] is seeking exclusion has been made aware of and understands the potential reliability impacts of said end-use customer’s load being excluded from the WRAP and include supporting correspondence to that effect."

The joint-ESPs believe examples must be provided of what reasonable customer education and supporting correspondence would entail for the purpose of load exclusion. 

For example, must the attestation specifically inform a customer that load excluded from WRAP may have their load curtailed in advance of declared contingency by the BAA?   If so, what documentation would be required?  Since WPP will not operate physical load shedding a (a BAA responsibility), then there are significant reliability issues for a non-BAAs to monitor and communicate any kind of preferential curtailment in advance to the customers. 

General Comment

Shell Energy North America (US), L.P and Calpine Energy Solutions, as joint-ESPs submit these comments as WRAP’s only non-BAA competitive energy service providers.  A few foundational matters to consider:

-Participants should discuss and WPP should clarify what are potential reliability implications, rights, and obligations for the Bulk Electric System as a whole and for individual customer loads which are excluded during times of sharing events or supply scarcity. 

-Given SPP Markets+ requires market participants (within a M+ BAA) to meet the WRAP standards, does this make WRAP participation effectively involuntary?  If not, how does WPP plant to accommodate loads which plan to exclude themselves from the program?