01. Please provide any comments on the proposal to adjust the timing of the FSPRM calculation (LOLE Study).
Tacoma Power appreciates the work of the Planning Reserve Margin Task Force and the opportunity to submit these comments. Tacoma Power also supports the proposal to establish Forward Showing Planning Reserve Margin values five years in advance of the applicable forward showing season. WRAP should enable participants to supplement their long-term planning with the regional diversity benefits of the program. This proposed timing will enable participants facing a deficiency to plan with a broader range of options to meet the deficiency rather than being forced to limit those options because of short deadlines.
The task force spent a meaningful amount of time considering and balancing the benefits and risks of various options to modify PRM calculations and timelines. This proposal on the timing of the FSPRM calculation, as well as other aspects of the Task Force proposal, represents a valuable compromise. Additional discussions should continue to consider other options to refine the FSPRM process, but this proposal should move forward expeditiously as a valuable step that represents a consensus of most WRAP participants.
02. Please provide any comments on modifying the duration of the Winter Binding Season.
Tacoma Power supports the proposed modifications to the duration of the Winter Binding Season. The existing Task Force proposal should move forward on its current timeline, allowing continued consideration of additional potential modifications that are suggested in this comment period.
03. Please provide any comment on the proposed updates to the methodology of the LOLE Study.
Tacoma Power supports the updates currently contained within the proposal that represent a compromise after extensive Task Force discussion balancing risks and benefits. Tacoma Power also supports the comments that have been submitted by Seattle City Light addressing high PRMs for June. The current schedule could accommodate Task Force discussion of whether any aspects of Seattle City Light’s suggestions could be incorporated into the current proposal and whether any are more appropriate for consideration in a subsequent process.
04. Please provide any comment on the Implementation Plan and Feasibility section of the proposal including Risks, Schedule, and Impacts.
Tacoma Power appreciates the careful work of the Task Force to develop a workable transition rollout and supports the Implementation Plan and Feasibility section.
05. Please provide any comments on the redlines to WRAP Tariff.
Tacoma Power does not have any additional comments specific to these redlines.
06. Please provide any comments on the redlines to BPM 101 – Advance Assessment.
Tacoma Power does not have any additional comments specific to these redlines.
07. Please provide any comments on the redlines to BPM 102 – Forward Showing Reliability Metrics.
Tacoma Power does not have any additional comments specific to these redlines.
08. Please provide any comments on the redlines to BPM 103 – Participant Forward Showing Capacity Requirements.
Tacoma Power does not have any additional comments specific to these redlines.
09. Please provide any comments on the redlines to BPM 104 – Capacity Critical Hours.
Tacoma Power does not have any additional comments specific to these redlines.
10. Please provide any comments on the redlines to BPM 105 – Qualifying Resources.
Tacoma Power does not have any additional comments specific to these redlines.
11. Please provide any comments on the redlines to BPM 108 – Forward Showing Submittal Process.
Tacoma Power does not have any additional comments specific to these redlines.
12. Please provide any comments on the redlines to BPM 109 – Forward Showing Transition Period.
Tacoma Power does not have any additional comments specific to these redlines.
13. Please provide any comments on the redlines to BPM 401 – New Participant Onboarding.
Tacoma Power does not have any additional comments specific to these redlines.
General Comment
Tacoma Power appreciates the careful and deliberate work of the Task Force Members with the support from the Western Power Pool and the Southwest Power Pool. This Task Force carefully discussed and balanced the risks and benefits of multiple options to help the WRAP PRMs contribute to the long-term success of WRAP and its individual members. The proposal represents a valuable compromise with the consensus of most Task Force members, representing a majority of WRAP participants. And forums exist to continue discussion and consideration on issues where the Task Force consensus is not unanimous.
Tacoma Power supports the suggestions of Seattle City Light to address the treatment of June within the proposal. The current treatment of June risks impacting other participants, including Tacoma Power, in the same way Seattle City Light describes, and Tacoma Power supports Seattle’s description of a disconnect between modeled requirements and actual system conditions for that month.
Seattle City Light proposes multiple options to mitigate this problem for June, including modification to the non-peak month status of June and establishment of a shoulder-month exception framework. Tacoma Power considers these options to be valuable enough to warrant consideration by the Task Force and WRAP stakeholders. At the same time, the current Task Force proposal represents a valuable compromise that should move forward expeditiously for the benefit of all WRAP participants while discussions on updating June PRM treatment continue.
Tacoma Power supports additional Task Force discussion to consider whether any of Seattle City Light’s alternatives can be incorporated into the current proposal under its existing timeline, and whether others can be expedited for continued discussion in a subsequent proposal.