01: Please supply any comments related to the Introduction, Definitions, or Background sections.
The Salt River Project Agricultural Improvement and Power District (SRP) appreciates the Western Power Pool’s (WPP) efforts in developing the Forward Showing (FS) Submittal Process Business Practice Manuals (BPM) for the WRAP. SRP suggest revising the FS Demonstration definition to more explicitly state it as a process where participants demonstrate they have met both their FS Capacity and FS Transmission Requirements, ensuring they have sufficient capacity and transmission capabilities for their obligations.
02: Please supply any comments related to the Forward Showing Submittal and Cure Period section (2).
SRP acknowledges the well-structured FS Submittal and Cure Period in the BPM. However, for added clarity, SRP recommends including more detailed guidance on curing FS Submittal deficiencies or referencing Section 14.5 of the WRAP Tariff which addresses this process. This would provide participants with clearer directions on addressing and rectifying any deficiencies.
03: Please supply any comments related to the Forward Showing Submittal Materials section (3).
No response submitted.
04: Please supply any comments related to the Forward Showing Submittal Materials - FS Demonstration section (3.1).
No response submitted.
05: Please supply any comments related to the Forward Showing Submittal Materials - Loads section (3.1.1).
No response submitted.
06: Please supply any comments related to the Forward Showing Submittal Materials section - Qualifying Resources section (3.1.2).
SRP appreciates the WPP's efforts in detailing guidelines for hybrid resources. SRP request that the WPP provide clarity on whether the total capacity of a hybrid resource (e.g., solar plus battery) should not exceed the interconnection limit, and if so, guidance on prioritizing which component (solar or battery) to reduce when the total exceeds the limit. This clarification may help participants accurately submit their Qualifying Capacity Contribution (QCC) for each component within the facility's overall limits.
07: Please supply any comments related to the Forward Showing Submittal Materials - Contracts section (3.1.3).
No response submitted.
08: Please supply any comments related to the Forward Showing Submittal Materials - Transmission section (3.1.4).
No response submitted.
09: Please supply any comments related to the Forward Showing Submittal Materials - Planned Outages section (3.1.5).
No response submitted.
10: Please supply any comments related to the Forward Showing Supporting Materials section (3.2).
No response submitted.
11: Please supply any comments related to the Forward Showing Supporting Materials - Testing section (3.2.1).
No response submitted.
12: Please supply any comments related to the Forward Showing Supporting Materials - Thermal Resources that are not Required to Report GADS Data section (3.2.2).
No response submitted.
13: Please supply any comments related to the Forward Showing Supporting Materials - Hydro Resources section (3.2.3).
No response submitted.
14: Please supply any comments related to the Forward Showing Supporting Materials - Late Registered Resources section (3.2.4).
No response submitted.
15: Please supply any comments related to the Forward Showing Supporting Materials - Transition Exceptions section (3.2.5).
No response submitted.
16: Please supply any comments related to the Cure Period section (4).
SRP values the WPP's work on the Cure Period section of the BPM. However, we recommend removing the phrase "to the satisfaction of the Program administrator" to minimize subjectivity. Additionally, SRP suggests that the WRAP provide a detailed checklist for participants to methodically complete their FS Submittal and address deficiencies. The checklist could be included in the Appendix of the BPM and provide participants a clear, step-by-step guide. Furthermore, it would be beneficial if the BPM included a commitment from the WPP to provide resources and dedicated staff assistance to help participants resolve any deficiencies effectively.
17: Please supply any comments related to Appendix A.
No response submitted.
18: Please supply any comments related to Appendix B.
No response submitted.
19: Please supply any comments related to Appendix C and D.
No response submitted.
20: Please supply any comments related to Appendix E.
No response submitted.
21: Please supply any comments related to Appendix F.
No response submitted.
22: Please supply any comments related to Appendix G.
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.