Western Resource Adequacy Program / Change Requests

Change Request 2024-CRF-008

Awaiting workplan review Enhancement

Request Summary

CAISO High-Priority Wheeling Through in WRAP

Co-sponsors

Arizona Public Service

Description Of Issue

CAISO refers to its firm transmission product as “high-priority wheeling through.” However, the current WRAP Tariff does not explicitly recognize this terminology or specify its equivalency to NERC priority 6 or 7. This creates ambiguity as to whether CAISO high-priority wheeling through qualifies as firm transmission under WRAP. This creates uncertainty for participants relying on CAISO high-priority wheeling through transmission to satisfy WRAP requirements. Without clear recognition, participants may experience compliance risks despite securing the highest available firm transmission from CAISO. 

Proposed Solution

Revise tariff sections 16.2.61, 16.2.6.2, and 20.6 to recognize CAISO high-priority wheeling through as equivalent to NERC Priority 6 or 7. 

Specific Document And Language

  • WRAP Tariff 

  • Sections: 16.2.61, 16.2.6.2, and 20.6 

    • 16.2.6.1 – affirmation of NERC priority 6 or 7 firm point-to-point transmission service rights or network integration transmission service rights from the identified resource to the point of delivery/load.  

    • 16.2.6.2 – there must be NERC priority 6 or 7 firm point-to-point transmission service rights or network integration transmission service rights from the identified resource to the point of delivery/load. 

    • 20.6 – Participant shall have in place, prior to the Operating Day, transmission service satisfying NERC priority 6 or 7 for each hour of such Operating Day for which a Sharing Event has been established 

Suggested Language Update

Introduce language that provides clarity on what qualifies as qualifying transmission to evaluate transmission products that do not explicitly use NERC Priority rating. A general definition of equivalent transmission and/or criteria for validating equivalence for non-NERC classified transmission products. 

Benefits

This change resolves uncertainty around transmission compliance by providing clarity for what qualifies as firm transmission under WRAP. Participants will gain confidence that high-priority transmission products that do not use a NERC Priority rating will satisfy WRAP requirements, which will streamline compliance.

Data Or Information

N/A