Change Request 2024-CRF-018

WRAP Tariff  (16.3) requires FS workbook demonstration of firm transmission from source to sink for 75% of the capacity used to serve P50 load +PRM.    Demonstration of firm transmission for 25% of the capacity used to serve P50 loads + PRM is not required. 

When PRMs approach or exceed 25% (March for example) it is possible to completely consume the 25% non-firm transmission buffer with PRM capacity.   

Consuming the 25% buffer with PRM capacity leaves participants with a requirement to demonstrate that 100% of capacity shown to serve P50 load is accompanied by source to sink firm transmission 7 months in advance of flow. Intent of the 75% transmission requirement was to recognize that at the Forward Showing time frame a participant may not have acquired 100% of the firm transmission needed to serve P50 peak load.    

Requiring firm transmission 7 months in advance for 100% of P50 peak load is problematic for many loads served by contracts (sourced from a system they qualify as WRAP capacity).   

Remove PRM from the Forward Showing Firm Transmission requirement calculation.    

Tariff section 16.3, FS Capacity Requirement:  Exclude PRM from 75% firm source to sink requirement.     

This change would recognize that Firm Transmission is a finite resource and that requiring firm transmission for the PRM causes purchase and holding of that limited transmission capability that is not readily available. Filing for exclusions on transmission requires constant monitoring and submittal to the program which causes an administrative burden.  Participants are still responsible for sharing in the Operations period, as a result the program already included the mechanism to incentives participants to be responsible in acquiring the required transmission to serve load and sharing ability.