01: Please supply any comments related to the Introduction, Definitions, or Background sections.
SRP values the approach of the BPM 102 to establish capacity needed to meet the reliability metric. For consistency and clarity, SRP recommends specifying the Loss of Load Expectation (LOLE) target as “1 event-day in 10 years LOLE per season” throughout the document. This adjustment may help ensure a common understanding among stakeholders.
02: Please supply any comments related to the Study Scoping Process section (3).
SRP appreciates the structured approach of the Study Scoping Process. SRP recommends the WPP clarify how the Board of Directors and RAPC comments are considered in the scoping process. This may improve transparency in the scoping process.
03: Please supply any comments related to the Load and Resource Zones section (4).
No response submitted.
04: Please supply any comments related to the Load and Resource Zones - Subregions Used for Determination of Monthly FSPRMs section (4.1).
No response submitted.
05: Please supply any comments related to the Load Modeling in the LOLE Study section (5).
SRP acknowledges the significance of accurate weather data. SRP prefers that the Sky Harbor Airport be utilized as the primary weather station for the Phoenix metro area. This weather station may better represent regional weather patterns that impact load.
06: Please supply any comments related to the Generator Modeling in the LOLE Study section (6).
No response submitted.
07: Please supply any comments related to the Generator Modeling in the LOLE Study - Thermal Generator Modeling section (6.1).
SRP recognizes the importance of accurately modeling forced outages for thermal resources in the LOLE Study. SRP requests clarification on whether forced outages for thermal resources are modeled stochastically in the LOLE study based on the time to failure and time to repair data provided from Generating Availability Data Systems (GADS). For greater clarity, SRP recommends explicitly stating in this section of the BPM whether such data informs the stochastic modeling of forced outages.
08: Please supply any comments related to the Generator Modeling in the LOLE Study - Storage Hydro Qualifying Resources section (6.2).
No response submitted.
09: Please supply any comments related to the Generator Modeling in the LOLE Study - Wind Resources section (6.3).
No response submitted.
10: Please supply any comments related to the Generator Modeling in the LOLE Study - Solar Resources section (6.4).
No response submitted.
11: Please supply any comments related to the Generator Modeling in the LOLE Study - Energy Storage Resources section (6.5).
No response submitted.
12: Please supply any comments related to the Generator Modeling in the LOLE Study - Run of River Qualifying Resources section (6.6).
No response submitted.
13: Please supply any comments related to the Generator Modeling in the LOLE Study - Demand Response Programs section (6.7).
SRP is interested in understanding why Demand Response (DR) resources are not modeled as Curtailment resources with emergency resource designation within the LOLE Study. SRP recommends including a clear explanation of this approach in the BPM.
14: Please supply any comments related to the Generator Modeling in the LOLE Study - Behind-the-Meter Generation section (6.8).
SRP request clarification on whether there is a minimum size threshold for Behind The Meter (BTM) resources to be included in the LOLE Study’s model.
15: Please supply any comments related to the Generator Modeling in the LOLE Study - External Capacity Modeling section (6.9).
No response submitted.
16: Please supply any comments related to the Generator Modeling in the LOLE Study - Contingency Reserves Modeling section (6.10).
SRP seeks details on the assumptions regarding the required response time for contingency reserves modeled in the LOLE Study, which may include criteria for 10 minutes, 30 minutes responses, or spinning reserves. Details on these assumptions may help ensure stakeholders have a thorough understanding of the modeling approach for contingency reserves.
17: Please supply any comments to the LOLE Study section (7).
No response submitted.
18: Please supply any comments to the FSPRMs Calculations section (8).
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.