01 Please supply any comments related to the Introduction, Definitions, or Background sections.
Please see general comments below for additional context.
The Introduction and Background sections are all fine, but we do not believe that they are necessary at this stage of WPP’s business practice development effort.
Please create a table of contents and a BPM that is dedicated to Definitions and Acronyms.
02 Please supply any comments related to the Resource Registration – Resource Eligibility and Timelines section.
Please post the Advance Assessment data request workbook. It might make sense for the guidance and instructions in the WPP Data Instruction Manual for providing resource registration information be part of this business practice as opposed to appearing in a separate document that content may be relevant to this business practice.
03 Please supply any comments related to the Resource Registration – Late Registration of Resources section.
For the use of terms in quotation, (e.g., ‘class average’ or ‘discounted’) please either define them as terms in a Definitions Business or consider replacing with a plain language description.
Please include the WPP Data Request Instruction Manual as part of business practices and supporting forms.
04 Please supply any comments related to the Resource Registration – Qualifying Resource Aggregation section.
Please identify the means by which the following should be communicated “For Qualifying Resources that are requested to be aggregated, the following information should be provided to the PO.” Can this be done within the Advance Assessment data request workbook?
05 Please supply any comments related to the Resource Registration – Generator Testing section.
Capability and Operations Tests of thermal resources sections not reviewed.
Please provide additional definition of the term Test. For example, is a Test satisfied simply by providing historical data that shows when a generator performed to a certain output amount under a given set of conditions? Or are there additional procedural requirements?
06 Please supply any comments related to the Resource Registration – Operational Testing section.
No response submitted.
07 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.
No response submitted.
08 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.
No response submitted.
09 Please supply any comments related to the Resource Registration – Provision of Test Reports in the FS Submittal section.
No response submitted.
10 Please supply any comments related to the Resource Registration – Testing for Late Registered Resources section.
No response submitted.
11 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Background section.
Please consider removing or consolidating content with sections above. At this point in the document, the term QCC has already appeared 40 times.
12 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Qualified Resources Included in FS Submittal That Have No QCC Previously Calculated section.
Please consider removing. It appears redundant with other sections in the business practice.
13 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Thermal Resources section.
No response submitted.
14 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Variable Energy Resources section.
QCC values for Variable Energy Resources represent a significant source of uncertainty for utility resource planning. Please make more explicit the frequency with which ELCC studies will be conducted to update QCC values. An updated study each season seems to be implied but is not explicitly stated.
Please make more explicit whether an average or marginal ELCC approach will be used to update QCCs for VERs (i.e. will existing wind/solar be grandfathered in at current ELCCs and new resources receive a QCC based on their marginal contribution or will existing resources receive progressively lower QCCs over time as more wind/solar is added?). Different parts of the BPM seem to suggest different answers.
The ELCC study section is informative and appreciated from a transparency perspective. However, it doesn’t describe activities performed by Participants; accordingly, it doesn’t help Participants meet requirements under the WRAP Tariff. This is an example of content that in the interest of time could have been added in later versions of the business practice.
15 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Energy Storage section.
What is the rationale for limiting the 2-hour storage QCC value to 50% of the 4-hour storage QCC? We would not necessarily expect ELCCs to be linear based on the duration of the storage. Why does the ELCC study itself not determine the QCCs?
16 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hybrid Facilities section.
The current methodology will need to be revisited at some point. There are plenty of studies out there suggesting that the ELCC of hybrid facilities is not equal to the sum of the ELCCs of each component. Typically, studies find that the ELCC of a hybrid facility is greater than the sum of the components.
17 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Demand Response section.
Is it an issue that ESRs can qualify with 2-4 hours of discharge but DR must be deployed for 5 hours to qualify? Should the treatment of ESRs and DR be consistent?
“The QCC value of the DR Qualified Resource is determined by multiplying the load reduction in MWs by the number of hours the resource can demonstrate load reduction capability divided by five” We are not sure we understand the mechanics here. For a DR resource that is capable of reducing demand for 5 hours this seems pretty straightforward, but what about a resource that is capable of demonstrating 20 hours of a 5MW reduction? Am I understanding correctly that it will get credited with a 20MW QCC despite only being able to provide 5MW?
“Testing for new DR programs in their first year of operation will be allowed if the Participant intends to claim QCC of more than 50% of the expected capability.” This was confusing to me. Is the program determining the QCC of the DR or is the Participant determining it? The previous section provided the calculation for determining the QCC, but this section seems to suggest that a Participant might claim a QCC of less than that.
Why does the Operational Test only require the DR program to achieve 50% of the stated capability? And for only 1 hour rather than the 5 hours it claims to be able to perform?
18 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hydro Resources section.
No response submitted.
19 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Other Resources section.
What is the definitional distinction between DR and customer resources? Maybe this is something to cover in the glossary.
20 Please supply any comments related to Appendix A.
Please consider integrating with the Hydro Resources section above.
General Comment
While we found Business Practice Manual 105 to be an insightful document, we struggled somewhat with it as a business practice. Our expectation of WRAP business practices is that they provide a set of instructions for WPP participants to perform so that they may achieve certain requirements of the WRAP tariff. This document seems to read more broadly, including processes occurring at the WPP or the Program Operator (PO). While we appreciate the WPP and PO being transparent about their activities, it sometimes causes confusion as to whether a particular activity is the responsibility of the WRAP participant, WPP, or PO. Other information included in the document including examples and background is likewise informative, but these sections do not directly help us meet our commitments under the tariff. As a result, we have found ourselves doing more searching and interpreting than we would normally expect in a business practice document. As WPP progresses with Business Practice development, we would encourage it do modify its approach along the following:
1. Publish an outline or title summary of all anticipated business practices
2. Publish a business practice that contains all acronyms and definitions
3. Publish any form or workbook identified in a draft business practice at the time of the draft business practice posting
4. In initial business practice versions, limit discussion of background, purpose, or examples and instead focus on developing concise documents that identify actions required of program participants.