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6/5/2020 4:05 PMWECC Comment Form - Satyal 2020-06-05T16_05_16VijaySatyalYesWestern Resource Advocates - Class 4
Western Grid Group (WGG), Northwest Energy Coalition ("NWEC") and Western Resource Advocates ("WRA") or also collectively as Public Interest Organizations ("PIOs") submit the following comments in response to the WECC 2020 Draft Near-Term Priorities document. At the outset, PIOs recognize the efforts invested into producing this report based off the WECC Reliability Workshop on February 20, 2020 and the Board Workshop on May 5, 2020.  At a strategic and policy level, the four priority areas are appropriate and relevant to the current reliability challenges facing the Western Interconnection. Recent bulk power system reliability events  have demonstrated the resiliency benefits of clean energy -- energy efficiency, demand response, distributed generation, diverse grid connected renewables. As WECC confronts risks emerging from wildfires and other public safety shutoffs, these resources are proving their worth and therefore deserve an equal examination in WECC's resource adequacy and system impact studies.PIOs raise two specific recommendations for WECC Staff consideration:1. Resource Adequacy and Performance: PIOs support the focus areas by WECC in regards to Resource Adequacy assessment by not only developing the Generation Resource Adequacy Forecast Tool (GRAF) but also leveraging the MAC RA Task Force to identify opportunities for future stakeholder engagement. PIOs however, do recommend WECC Staff to leverage the GRAF tool and integrate where possible with the System Adequacy team's production cost modeling expertise to evaluate very near-term and near-term scenarios with different sensitivities of RA across the WECC footprint. Specifically, PIOs recommend WECC staff to develop RA specific resource mix studies that harness the intellectual contributions from the June 11 RA Forum to assess near-term (years 5 or lesser) reliability impact assessments of changing RA levels. Adding in varying levels of variable energy resources would enhance the analyses of determining RA across WECC footprint. PIOs further recommend additional outreach with the GRAF tool.2. Changing Resource Mix: PIOs support the driving factors identified on Page 5 that warrant an assessment of the changing resource mix and its impact to Bulk Power System across Western Interconnection. As agreed in the Reliability Summit (February 20, 2020), economic factors including the evolution of regional markets and reduced dependence on bilateral markets, continue to influence reliability through impacts to bulk power transmission flows. Therefore, PIOs recommend WECC Staff to consider evaluating the impacts to transmission congestion as a result of markets induced flow-based transmission, reduced curtailment of renewable energy resources and the frequent cycling of fossil fuel based baseload power plants (that's taking place in ways not expected and planned before). In summary, without modeling specific market initiatives per se but assuming for market expansion efforts generically, WECC staff could assess reliability impacts of expanding non-bilateral market efforts to the resource mix. Specifically, PIOs recommend an explicit consideration of market trends and market practices as a sensitivity or scenario in the power flow and production cost analyses by WECC’s System Stability and System Adequacy teams and by leveraging the use of the 2030 Anchor Data Set.We welcome any questions on the above comments. Vijay Satyal (on behalf of NWEC, WRA and WGG) - 
6/5/2020 3:43 PMWECC Comment Form - Blackney 2020-06-05T15_43_01RobertBlackneyYesSouthern California Edison Company - Class 1
SCE has some comments incremental to the comments provided via file upload. Specifically, regarding WECC's Near-Term Priorities outlined under Section 3, i.e., Extreme Natural Events, SCE believes that WECC's recommendation is a good step towards understanding risks on interconnections associated with extreme events (natural or pandemic). Further, SCE believes that understanding how individual state and utility assess their system vulnerabilities and expected performance levels associated with various extreme events will be beneficial in evaluating potential impacts to interconnections. Additionally, this understanding will also help to develop guidance on the appropriate levels of preparation necessary to ensure the reliability and security of the interconnection.
6/5/2020 3:36 PMWECC Comment Form - Blackney 2020-06-05T15_36_52RobertBlackneyYesSouthern California Edison Company - Class 1
6/5/2020 12:41 PMWECC Comment Form - Cook 2020-06-05T12_41_09JeffCookYes