01: Please supply any comments related to the Introduction or Definitions sections. (1)
No response submitted.
02: Please supply any comments on the Demand Response Utilization section. (2)
No response submitted.
03: Please supply any comments on the FS Capacity Requirement section. (3)
No response submitted.
04: Please Supply any comments on the P50 Peak Load Forecast section. (4)
Comment applies to both sections 4.1 and 4.2: Tacoma Power is concerned that limiting the Monthly P50 Peak Load Forecast methodology to just five seasons with a single datapoint for each will either under- or over-estimate a participant’s load from year to year. Tacoma has used the current methodology in order to predict its P50 Peak Load Forecast in future seasons and anticipates a sudden substantial change to the resulting P50 that does not necessarily reflect the change in Tacoma’s load.
Tacoma Power supports the reasoning behind using the median over the mean (median being resistant to outliers). But paired with the small sample size the median can also produce skewed results.
Tacoma Power does not have an alternate proposal at this time but would be interested in refining the methodology in the future with the aim of producing more consistent results from year to year.
Regarding modifying the P50 Peak Load Forecast results to account for load removal or addition: Would incorporating the change in load into the historical data be a valid way to calculate the max for each season and the median for the five-year period? Rather than applying a modifier to Monthly P50 results calculated using unaltered historical data?
05: Please Supply any comments on the P50 Peak Load Forecast - Winter P50 Peak Load Forecast section. (4.1)
Labeling Table 1 with the specific Winter Season to which the example data applies would increase clarity.
06: Please Supply any comments on the P50 Peak Load Forecast - Summer P50 Peak Load Forecast section. (4.2)
Labeling Table 2 with the specific Summer Season to which the example data applies would increase clarity.
The references to previous steps in this section need to be double checked.
07: Please supply any comments on the Load Growth Factor section. (5)
Suggest including an example of how/when the Load Growth Factor should be applied (its application is noted at the end of sections 4.1 and 4.2 but the result is not shown in the examples).
08: Please supply any comments on the Load Growth Factor - Established Growth Rate section. (5.1)
No response submitted.
09: Please supply any comments on the Load Growth Factor - Participant Alternative Growth Rate section. (5.2)
No response submitted.
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)
No response submitted.
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)
Does the LOLE Study account for new load additions or removals from the region? Account for participants that use a different Load Growth Factor? (Please ignore if this is or will be described in another BPM).
17: Please supply any comments related to the Appendices.
No response submitted.
General Comment
Tacoma appreciates the opportunity to comment on BPM 103, as well as WPP’s responsiveness to and engagement with participants.