01. Please supply any comment related to the proposed changes in the Tariff.
SRP appreciates BPA’s NTFP and understands that due to challenges related to long-term firm transmission availability, the intent of this NTFP is to remove the PRM from the Forward Showing transmission requirement by attaching the requirement to only P50 load, as opposed to P50 load + PRM. However, SRP requests additional details on expected program impacts, such as one or two examples that show the before and after transmission requirement and how the removed PRM portion of the transmission requirement is expected to be managed between the Forward Showing and Operations Program. SRP is not opposed to further review of this concept, but to ensure the success of the program and mitigate unintended outcomes, SRP recommends that this be evaluated through a collaborative participant discussion before any permanent change is adopted.
02. Please supply any comment related to the proposed changes in BPM 106.
No response submitted.
03. Please supply any comment related to the proposed changes in BPM 107.
No response submitted.
04. Please supply any comment related to the proposed changes in BPM 108.
No response submitted.
General Comment
SRP encourages BPA and the WPP to facilitate a collaborative task force discussion among WRAP participants before a permanent program change is adopted, to help ensure participant alignment.
SRP recognizes long-term firm transmission can be exceptionally difficult to identify and procure, which is why firm transmission is a critical element of the WRAP Forward Showing. SRP acknowledges that Forward Showing requirements for firm transmission may create an artificial undersupply of qualifying transmission rights relative to the aggressive procurement that could result from unnecessarily severe firm transmission requirements.
SRP understands that transmission from resources to load is a critical element of resource adequacy, and that planning entities often account for load forecast error in transmission procurement. SRP believes that many entities use P90 or otherwise “high” load forecasts for internal transmission planning, a risk-averse path to mitigate the exceptional challenge in procuring new transmission, including in the near-term. Recognizing that WRAP only includes one load forecast as part of the Forward Showing, the current language (P50 + PRM) may be a reasonable treatment to yield similar risk-averse treatment.
The current 75% treatment is a clear acknowledgment that 100% transmission coverage is not required by the time of Forward Showing submittal. However, SRP believes that collaborative discussions may help ensure that a reduction in the firm transmission requirements appropriately reflects a consensus view on how transmission supports resource adequacy. Prior to broad changes, SRP would support discussion of tradeoffs accepted with firm transmission requirement reductions for WRAP participants.
SRP also recommends consideration be given to timing and prioritization of ongoing efforts within WRAP. From SRP’s perspective, it may be beneficial to focus first on getting foundational WRAP processes in place before adopting permanent changes that materially revise firm transmission demonstration requirements.