01: Please supply any comments related to the Introduction or Definitions sections. (1)
SRP appreciates the definitions provided in BPM 103. However, SRP requests enhanced and clearer definitions for ‘Contingency Reserve Adjustment – Load’ and ‘Super Peak Months.' For the ‘Contingency Reserve Adjustment – Load’, it would be helpful to include information on criteria related to how load adjustments are calculated and applied. For ‘Super Peak Months,’ clarification would be helpful on the rationale and criteria for the selection of these months, and how they differ from other months.
02: Please supply any comments on the Demand Response Utilization section. (2)
SRP believes that a participant’s selection of Demand Response (DR) Utilization treatments can materially impact their forward showing obligation and regional reliability. Options providing a load reduction credit would allow for the participant to avoid carrying Planning Reserve Margin on DR capacity, while DR’s treatment as a resource would require participants to carry planning reserve on load removing the impact of DR.
Further, a participant’s selection of DR treatment options appears to change the load component to which the Load Growth Factor is applied. Therefore, a utility’s selection will determine whether the forward showing load includes load growth on their DR capacity.
SRP believes that Option 2 is most consistent with industry best practices and may serve as the benchmark by which other proposed options can demonstrate parity. In SRP’s evaluation, both Option 1 and Option 3 reduce a participant’s obligation relative to Option 2 under many circumstances, though Option 1’s exclusion of incremental DR benefits can be harmful to participants who select Option 1 while expecting to expand their DR portfolio. It appears that Option 3 would generally produce the lowest level of Forward Showing responsibility with DR growth, and SRP is concerned that high utilization of this option may degrade regional reliability.
SRP values appropriate and consistent consideration of DR across WRAP participants. SRP appreciates the flexibility provided to allow participants to choose a method for incorporating DR into their load forecasts, but SRP requests adjustments to ensure that a participant’s obligation and contribution to regional adequacy are equivalent across the available treatment options.
The first bullet appears to have an unresolved parenthesis in the last line - (see Section 4 ultimately leading to lower Monthly FS Capacity Requirements.
03: Please supply any comments on the FS Capacity Requirement section. (3)
The paragraph implies that the monthly Demand Response Load Modifier is known as the “FS Capacity Requirement Unadjusted”. SRP understands that the intent is to define the net result after adjustment by the monthly Demand Response Load Modifier as the “FS Capacity Requirement Unadjusted”, SRP recommends more clearly attaching “FS Capacity Requirement Unadjusted” to the net result.
SRP appreciates the Equation 1 detail, which was useful to understand the intent of this section.
04: Please Supply any comments on the P50 Peak Load Forecast section. (4)
SRP appreciates BPM 103 including the methodology for the P50 Peak Load Forecast but requests further clarity on the integration of a load growth factor. It is not clear if the load growth factor should be applied to the forecast for the upcoming (current) forecast year or only for years further out in the forecast horizon (future years). The current methodology suggests using the median of the last 5 years as the forecast, which may underestimate future loads for growing systems. SRP believes that the upcoming (current) forecast year forecast value should also have the annual growth factor applied to it. SRP recommends detailing in the BPM how and when to apply the load growth factor in the provided examples. Additionally, extending the examples through all steps (1-6) will provide more transparency and clarity for participants.
05: Please Supply any comments on the P50 Peak Load Forecast - Winter P50 Peak Load Forecast section. (4.1)
SRP request clarification on the rationale for having a different methodology for winter compared to summer. Specifically, SRP inquires the purpose of the “Super Peak” months in the winter and whether the ratios used in the summer could be applicable in the winter as well. Understanding the reasoning behind these differences may be helpful for WRAP participants.
SRP suggests expanding the example spreadsheet posted on the WPP website to include all steps (1-6) rather than the current subset of steps 1-4.
06: Please Supply any comments on the P50 Peak Load Forecast - Summer P50 Peak Load Forecast section. (4.2)
SRP suggests expanding the example spreadsheet posted on the WPP website to include all steps (1-6) rather than the current subset of steps 1-5.
07: Please supply any comments on the Load Growth Factor section. (5)
No response submitted.
08: Please supply any comments on the Load Growth Factor - Established Growth Rate section. (5.1)
SRP requests clarification on which growth drivers are accounted for in the existing 1.1% growth rate. A 1.1% growth rate may be a reasonable proxy for current expectations but may quickly become outdated as expectations for growth increase along with the national trends of industrial onshoring and data center expansions; as seen this past year where growth forecasts doubled according to the National Load-Growth Report-2023 (gridstrategiesllc.com). Therefore, SRP suggests WRAP be actively updating the Load Growth Factor annually and SRP recommends incorporating a mechanism to adjust the growth rate regularly, to include more localized and current data. Underestimating load growth reduces the requirements for participants and may cap the amount participants are required to share at a level below what is needed for adequacy. In addition, SRP suggests eliminating “could potentially” from the sentence “A WRAP-wide established growth rate (or set of established growth rates) could potentially account for location, whether Participant type, Participant customer composition (balance between retail, commercial, and industrial)” and replacing it with “may.”
By way of example, the 2023 Western Assessment of Resource Adequacy report conducted by WECC projects a 1.64% compound average annual growth rate for WECC peak demand growth and 1.74% compound average annual energy growth from 2024-2033, based on SRP’s calculation of a 9-year anticipated growth rate from values provided by the report (wecc.org). These figures reflect the latest load forecasts provided to WECC by regional load serving entities. Referencing this WECC report or a published analysis with similar expectations for annual updates may provide opportunities for updating growth rates to prudently meet anticipated reliability needs.
The 2023 Western Assessment of Resource Adequacy also provides load growth rates at a sub-regional level, which could be mapped to WRAP participants to better reflect expected growth within the WRAP footprint.
09: Please supply any comments on the Load Growth Factor - Participant Alternative Growth Rate section. (5.2)
SRP encourages the WPP to review the requirement that the alternative growth rate must produce a load forecast difference of at least 5% from the established growth rate. A difference of at least 5% is a high bar, as a 5% difference for a 10,000MW peak translates to a significant 500MW. SRP suggests consideration of a lower relevance threshold, e.g. at least a 2% difference in future load from the established growth rate. This lower threshold could potentially make it more feasible for participants to propose and justify alternative growth rates.
As a related concern, there is seemingly no clear incentive for participants to voluntarily report a higher growth rate under the current high threshold."
10: Please supply any comments on the Contingency Reserves Adjustment section. (6)
No response submitted.
11: Please supply any comments related to the Contingency Reserves Adjustment - Contingency Reserve Adjustment-Generation section. (6.1)
No response submitted.
12: Please supply any comments related to the Contingency Reserves Adjustment - Contingency Reserve Adjustment-Load section. (6.2)
SRP reiterates that the definition of “Contingency Reserves Adjustment – Load” is vague and can be improved for clarity. SRP encourages the WPP to provide clear examples in the BPM of how adjustments are calculated and applied in different scenarios.
13: Please supply any comments related to the Excluding Load section. (7)
No response submitted.
14: Please supply any comments related to the Submitting Loads from Multiple Subregions section. (8)
No response submitted.
15: Please supply any comments from the Load Aggregation/Disaggregation section. (9)
No response submitted.
16: Please supply any comments related to the LOLE Study Load Forecast and Load Growth Rate section. (10)
No response submitted.
17: Please supply any comments related to the Appendices.
No response submitted.
General Comment
SRP is encouraged by the WPP’s ongoing efforts in the developing of WRAP BPMs and has provided comments on relevant sections within this BPM.
An understanding of future load growth projections is critical for the Western Resource Adequacy Program to support resource adequacy. Continuing participant discussion and BPM 103 refinement will provide sufficient certainty that the Western Resource Adequacy Program is realistically assessing and meeting regional needs.