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.
Shell Energy strenuously opposes the normal resource registration timelines which requires 18-month to 24-month lead times in advance of being eligible for WRAP RA. This does not reflect the manner in which new resources are developed and attain commercial operations, nor reflect the contracting realities of prospective non-utility WRAP participants. For instance, presuming registration is required post-COD, this would lead to a roughly 18-month delay between a resource COD and realizing capacity value under WRAP. This would unnecessarily increase costs for end users. The normal timeline should be more abbreviated, Shell Energy would suggest resources registered and validated be eligible to realize WRAP capacity value for the prompt FS period, requiring registration 7-8 months in advance of a FS period.
03 Please supply any comments related to the Resource Registration – Late Registration of Resources section.
Shell Energy appreciates the ability to utilize a late resource registration option inside the proposed 18-month window; however, limiting the resource to providing a maximum of 10% of an LRE's FS capacity requirement is without merit. For instance, should a LRE count any one resource to provide a majority of the LRE's FS capacity requirement, under the proposed BPM the LRE must contract for additional capacity -- at great expense burden to the LRE's customers/ratepayers. Shell Energy suggests this 10% limit be subject to a waiver process should WPP and the RAPC find this threshold is demonstrably essential.
Especially for new builds, development of said incremental resources require a level of quality and sophistication likely meeting the reliability standards of an RA program; said another way, Shell Energy believes almost no resources under development today will be unreliable jalopies. Accordingly, the 10% threshold is too conservative and not fit for purpose.
04 Please supply any comments related to the Resource Registration – Qualifying Resource Aggregation section.
Shell Energy opposes the requirement that aggregated qualified resources less than 1 MW be located within 10 miles of each other. It appears this will disqualify many behind the meter resources unnecessarily from providing benefits to the participating resource owner/contract holder and the wider program footprint.
05 Please supply any comments related to the Resource Registration – Generator Testing section.
No response submitted.
06 Please supply any comments related to the Resource Registration – Operational Testing section.
No response submitted.
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.
No response submitted.
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
Shell Energy North America (US), L.P. ("Shell Energy") appreciates the opportunity to submit comments on the Section 105 -- Qualifying Resources BPM.