Submitted Comments on Clarification of Station Service Language |
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12/12/2011 Seneca Sustainable Energy, LLC does not support any change to the existing Station Service definition. Todd A. Payne Seneca Sustainable Energy, LLC |
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12/9/2011 I don't believe that the station service definition is one that should be changed or determined by Wregis. Station service is typically defined explicitly in PPA between a generator and the power purchaser. If it is not, than the QRE should have a process for determining station service load. You will most likely create a circumstance where your definition of station service is substantively different than what is commonly accepted, which would create additional confusion. Kyle Freres Evergreen BioPower LLC |
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12/9/2011 LotusWorks does not support changing the current definition of Station Service. Steven Ostrowski LotusWorks |
| 12/9/2011
Grays Harbor Public Utility District opposes the proposed changes to the definition of Station Service because the current definition is clear and concise. Furthermore, adding language and giving examples of what Station Service includes or does not include should be determined by the State Authoritative and or Government entity established to define what is renewable and in compliance with the Renewable Portfolio Standards of that state. Melinda James Grays Harbor PUD |
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12/9/2011 To view comments on this topic submitted by California Biomass Energy Alliance, please click here. Julee Malinowski-Ball, Executive Director CBEA |
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12/9/2011 SCE does not support the proposed changes to the definition of Station Service submitted by WECC because the change would reduce the amount of eligible renewable resources SCE’s customers are entitled to receive through Power Purchase Agreements (PPA) secured on their behalf. The current definition is well understood in the renewables market and is part of existing PPAs with SCE. WREGIS’s current definition of Station Service should stand without additional changes. Sergio Islas Southern California Edison |
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12/9/2011 Mink Creek Hydro requests that there be no change to the language defining Station Service which currently exists in the WREGIS Operating Rules. The existing definition is adequate and should not be changed. Rob Fackrell Mink Creek Hydro, LLC |
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12/8/2011 Community Renewable Energy Service, Inc supports the existing language for station service. We do not support any change to the existing language. John Richardson, Vice President Community Renewable Energy Service, Inc |
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12/8/2011 SDG&E supports leaving the language as it currently is where Station Service is defined as just the energy that is used at the generation facility. Linda Watts San Diego Gas & Electric |
| 12/7/2011
Idaho Power believes the existing definition of station service in the WREGIS Operating Rules is adequate, represents the industry standard, and should not be changed. Mark Stokes Idaho Power |
| 12/7/2011
Phoenix Energy, similar to Kiara Solar has existing PPA agreements. A change in “Station Service” definition will change the REC’s supplied to our customer and jeopardize existing bank funding based on the value of the REC’s in the signed PPA’s. Phoenix Energy supports existing definition language or “Parasitic Load” language as proposed in Shell Energy’s comment dated 11/21/11 and in accord with industry standards. Paul Elias, Energy Development Phoenix Energy |
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12/7/2011 Xcel Energy supports the definition of station service proposed by Shell Energy, ““Station Service - The electric supply for the ancillary equipment used to operate a generating station or substation while it is generating electricity. Also called ‘Parasitic Load,’ it is the power that is consumed by the Generating Unit to produce electricity.” However, we would also propose to add the following sentence, “State Program Administrators retain the authority to determine if station service, as defined by WREGIS, is eligible to be used for renewable energy programs and/or mandates within their states.” Also, we would propose to add a sentence in Section 9.6 that states that the requirement to register multiple meters to measure the on-site load is not applicable to customer-sited generation. Kari Chilcott Clark, Renewable Energy Portfolio Manager Xcel Energy |
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12/7/2011 Terra-Gen Operating Company, LLC does not support the proposed revision to the definition of station load. Ellen Allman, Senior Business Manager Terra-Gen Operating Company, LLC |
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12/7/2011 The Sanitation Districts of Los Angeles County support either the existing language or the language proposed by Shell Energy. These are both clean definitions in accord with industry standards. Mark McDannel, Energy Recovery Engineering Section Los Angeles County Sanitation Districts |
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12/06/2011 TransAlta Corporation supports the proposed language offered by Shell Energy whereby station services is limited to the energy that is used at the generation facility to produce electricity. We believe the following definition to be clear and concise: “Station Service - The electric supply for the ancillary equipment used to operate a generating station or substation while it is generating electricity. Also called ‘Parasitic Load,’ it is the power that is consumed by the Generating Unit to produce electricity” Thank you for considering our comments. Oliver Bussler, Director Commercial Management West TransAlta |
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12/05/2011 Broadrock Renewables, LLC supports the proposed language offered by Shell Energy. The proposed definition properly addresses the issue and allows for a clear understanding of true “parasitic load”. Further, Broadrock urges WREGIS staff to resolve this matter forthwith. The potential, and yet unresolved, modification is creating uncertainty in the marketplace and discouraging parties from finalizing important contract negotiations. It is imperative that the issue is addressed correctly and without haste. Stephen Galowitz & Delaney L. Hunter Broadrock Renewables |
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11/30/2011 Kiara Solar is not in favor of this change. We have an existing PPA agreement, and this change in definition will retroactively change the number of RECs we can supply to our customer. At a minimum this change should exempt existing agreements. This will create an additional clerical burden for our staff, in that they will now have to gather information on our lumber mill partners’ use of power and factor that into our WREGIS reporting. Lew Rubin Kiara Solar |
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11/30/2011 We do not support any attempt by WREGIS to make alterations to the existing definition of station service. Station service is: The electric supply for the ancillary equipment used to operate a generating station or substation while it is generating electricity. Also called “Parasitic Load,” it is the power that is consumed by the Generating Unit to produce electricity. We would ask that WREGIS recognize this industry accepted definition, and stop attempting to expand it to loads that are not associated with the generation of electricity. Halley Dickey, Director Geothermal Business Development Renewable Energy Systems |
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11/29/2011 IPT would agree with previous the previous comments which reflect a long held understanding of the term Station Service or Parasitic Load within the generating community. We concur that Station Service should be defined as: Station Service: The electric supply for the ancillary equipment used to operate a generating station or substation while it is generating electricity. Also called “Parasitic Load,” it is the power that is consumed by the Generating Unit to produce electricity. A change to an accepted term, used in both general terminology as well as and perhaps more importantly, as an integral part of contract language in the generating industry could have significant repercussions and unintended consequences throughout the industry.
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11/21/2011 Cyrq Energy would like to propose the following language in response to request for guidance to the working group to help procure a clear definition of “station service” in WREGIS. Station Service: The electric supply for the ancillary equipment used to operate a generating station or substation while it is generating electricity. Also called “Parasitic Load,” it is the power that is consumed by the Generating Unit to produce electricity. We believe that this language makes it clear that Station Service is limited to the energy that is used at the generation facility to produce electricity. We further believe proposing to include within the definition of “Station Service” electricity utilized for the conveyance or transfer of fuel to a generating station creates a subjective standard, and is proposing a change that is contrary to the commonly used industry definition by organizations such as FERC. Scott Rhees Cyrq Energy |
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Shell Energy would like to propose the following language in bold below. Station Service: The electric supply for the ancillary equipment used to operate a generating station or substation while it is generating electricity. Also called “Parasitic Load,” it is the power that is consumed by the Generating Unit to produce electricity. I believe that this language makes it clear that Station Service is limited to the energy that is used at the generation facility to produce electricity. Marcie Milner, VP Regulatory Affairs Shell Energy North America |
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Please click here for Bill Chamberlain's revised definition of Station Service. Bill Chamberlain WECC |
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