01: Please supply any comments related to corrections in the Definitions Section
The definition of “Central Hub” may benefit from clarification that the WRAP program identifies central hubs, and that they are not solely the result of an examination of the physical transmission network.
SRP encourages clarification if the Aggregate Capacity Deficiency is intended to be calculated for each month within a binding season or if is it intended to be coincident.
02: Please supply any comments on redlines to Tariff section 7 (Credit Requirements and Settlement for Holdback and Delivered Energy)
Overall, the 90-day window is adequate, but the Tariff should specify whether this period refers to calendar days or business days to ensure clarity. Additionally, in 7.2.1, the term ‘data inputs’ needs to be clearly defined. It should specify if the intent is to allow disputes related to the ‘price formation’ calculation but not other aspects of settlements such as MWhs.
03: Please supply any comments related to redlines to Tariff section 10.2 (Treatment of Confidential or Commercially Sensitive Information)
SRP is supportive of the proposed tariff revisions in section 10.2, which will reduce the consequence of a WRAP participant inadvertently providing confidential data without appropriate labeling, which would declassify the confidential information under the current tariff language.
04: Please supply any comments related to redlines to Tariff sections 14.2.1.2, 16.1.5, and 19.2 (relating to Forward Showing Submittal demonstration of inter- subregional transmission in lieu of Capacity)
No response submitted.
05: Please supply any comments on redlines to Tariff sections 16.1.2.1, 16.1.2.3, and 16.2.5.2.2 (related to corrected "annual LOLE" references to "Seasonal LOLE")
SRP is supportive of the proposed tariff revision to modify annual LOLE references to be season-specific. While this revision indicates that WRAP will target two events in 10 years, SRP believes that entity-specific resource adequacy risk is likely to be concentrated in one of the two operational seasons.
06: Please supply any comments on redlines to Tariff sections 16.1.2, 16.2.5.4, 20.1.1 (related to options for DR)
SRP has provided comments to proposed BPM 103 to advocate for capacity value parity between participant election for Demand Response treatment.
SRP would prefer that the QCC determination be handled in a business process manual, perhaps capped in the tariff by “multiplying the load reduction in MWs by the number of hours the resource can demonstrate load reduction capability divided by five.” Specifics of Demand Response programs (such as the number of times that a program can be utilized in a week or a year) may limit QCC beyond the calculation in the tariff language. Retaining the ability to consider these details in QCC calculations without a tariff revision may be valuable to WRAP.
SRP recognizes that SRP’s preferred tariff treatment of DR QCC would be a departure from existing tariff language intent, and SRP is willing to support the collective proposed revisions, deferring additional revision to other processes.
07: Please supply any comments on redlines to Tariff section 16.2.7 (relating to Total RA Transfer)
SRP is supportive of the clarifying proposed revision to section 16.2.7.
08: Please supply any comments on redlines to Tariff section 16.2.8 (relating to Planned Outages)
SRP is supportive of the proposed correction to section 16.2.8.
09: Please supply any comments on redlines to Tariff section 16.3.2 (relating to Transmission Exceptions)
SRP is supportive of the proposed correction to section 16.3.2. Without the revision, the detail associated with exceptions may incorrectly be interpreted as part of section 16.3.2.4, when the detail is intended to apply to all four transmission exception categories.
10: Please supply any comments on redlines to Tariff sections 17.2.7 and 17.2.8 (relating to Forward Showing Deficiency Charge)
In section 17.2, SRP suggests removing the phrase “consisting of a Summer Season and the immediately succeeding Winter Season”, as the phrase is out of place in a three-part list and is already included in the defined term “Forward Showing Year”. SRP supports the corrections in 17.2.7 and 17.2.8.
For 17.2.9, suggest adding “previous” for clarity - “Notwithstanding Sections 17.2.7 and 17.2.8, if there is either a Summer % Deficit or a Winter % Deficit if a Participant incurred any FS Deficiency Charges in a previous Forward Showing Year...”
11: Please supply any comments on redlines to Tariff section 19.1 (relating to Operations Program Timeline and Supporting Information
No response submitted.
12: Please supply any comments on redlines to Tariff section 19.4 (relating to Operations Program Timeline and Participant Tx Inputs)
No response submitted.
13: Please supply any comments on redlines to Tariff section 19.5 and 20.4.1.2 (relating to reference correction of Subregions not containing a central transmission hub)
Section 19.5 is difficult to interpret, possibly due to extra commas or suboptimal placement of the “ending on the Preschedule Day” detail.
14: Please supply any comments on redlines to Tariff section 19.5 (relating to decription of mechanics of Voluntary Holdback)
No response submitted.
15: Please supply any comments on redlines to Tariff section 20.1.1 (relating to update to description of Sharing Calculation)
SRP is concerned that Demand Response Load Modifier treatment enjoys an unwarranted capacity benefit beyond Demand Response Capacity Resource treatment due to avoided planning reserve requirement. SRP does not believe that electing to treat demand response resources as load modification would have a legitimate resource adequacy benefit over capacity resource treatment, and SRP strongly advocates for algebraic parity in the sharing calculation between the two treatment methods. SRP has provided related comments in response to the draft BPM 103.
SRP supports the other formulaic corrections in the Sharing Calculation, especially including the inclusion of a participant’s full Contingency Reserve Obligation.
SRP advises that the definition for Uncertainty Factor appears to be errantly included twice in the definition list.
16: Please supply any comments on redlines to Tariff section 20.1.3 (relating to removal of references to lesser priorities of Energy Deployment)
No response submitted.
17: Please supply any comments on redlines to Tariff section 20.2 (relating to description of mechanics of Holdback Requirement)
No response submitted.
18: Please supply any comments on redlines to Tariff section 20.4.1 (relating to how Energy Deployment occurs on Operation Day)
No response submitted.
19: Please supply any comments on redlines to Tariff section 20.4.1.2 and 21.1.4 (relating to reference corrections)
No response submitted.
20: Please supply any comments on redlines to Tariff sections 20.4.2-20.2.4 (relating to corrections to 85 & 80 minutes before the hour)
No response submitted.
21: Please supply any comments on redlines to Tariff section 20.8.1 (relating to incorrect conflation of "Raise Hand" with Voluntary Holdback)
No response submitted.
22: Please supply any comments on redlines to Tariff section 21.2.4 (relating to updating Energy Declined Settlement price to be the Applicable Real-time Index Price for the hour)
No response submitted.
23: Please supply any comments on redlines to Tariff section 21.2.5 (relating to change to Make Whole Adjustment formula)
SRP has identified an error in the revised text. To be consistent with the revised formula, the revised text should say “The Make Whole Adjustment has a MINIMUM value of zero and is determined as follows...”.
General Comment
SRP supports the proposed tariff revisions that correct issues and facilitate participants effective utilization of WRAP. SRP appreciates the WPP’s efforts in revising the tariff to align with intended policy and improve the functionality of WRAP. SRP looks forward to reviewing the final version of the tariff to ensure the program will effectively work for all participants.