Change Request 2024-CRF-007

Need clarity on treatment of CAISO High Priority wheel through and non-RA high priority exports. Current language represents NERC Priority 6 and 7 clearly, but CAISO rules are distinct from traditional NERC Priority 6 and 7.

Update areas of the WRAP Tariff and BPM language that specify NERC Priority 6 and 7 to also include CAISO language on High Priority Wheels and exports.

WRAP Tariff section 16.2.6.1
WRAP BPM 106 Section 3.1
 

Tariff section 16.2.6.1

Absent one of the exceptions described and limited below, capacity supply agreements qualifying for a Net Contract QCC in the WRAP must be resource specific, and therefore must include, among other requirements, an identified source, an assurance that the capacity is not used for another entity’s resource adequacy requirements, an assurance that the seller will not fail to deliver in order to meet other supply obligations, and affirmation of NERC priority 6 or 7 firm point-to-point transmission service rights or network integration transmission service rights for non-CAISO transmission, or Priority Wheel Through export eligibility for CAISO transmission, from the identified resource to the point of delivery/load. The specific resources identified in a capacity supply agreement qualifying for Net Contract QCC shall meet the same Resource QCC accreditation requirements for the given resource type, as specified in Section 16.2.5.

BPM 106 Section 3.1

iv) non-CAISO: there is an affirmation that the energy will be delivered on NERC Priority 6 or NERC Priority 7 point-to-point transmission service or network integration transmission service (NITS) rights from the resource to an identified Contracted Capacity Firm Delivery Point; CAISO: Priority Wheel Through export eligible transmission from the resource to an identified Contracted Capacity Firm Delivery Point; and

Program clarity on requirements to treat CAISO transmission service as firm deliverability from the identified resource to the Participant’s load.