WESTERN RESOURCE ADEQUACY PROGRAM | CHANGE REQUESTS

CHANGE REQUEST 2025-CRF-001

CHANGE | STATUS - NTFP CONFIRMED | Submitted Jan. 8, 2025, 4:09 p.m.






Summary:


BPM changes resulting from the Revised Transition Plan (2024-EP-001) and housekeeping

Co-sponsors (optional):


-


Provide a description of the issue:


In November 2024, Western Power Pool (WPP) submitted two FERC 205 filings to the Federal Energy Regulatory Commission (FERC) proposing changes to the WRAP Tariff outlined in Proposals 2024-EP-1 and 2024-NTFP-1. The WRAP Business Practice Manuals (BPMs) require a series of corrections in response to updates to Tariff language included in these filings. The timeline of events leading to the changes described in this document is as follows.

On April 22nd , 2024, the Resource Adequacy Participant Committee (RAPC) published a letter to the region reaffirming commitment to the program and highlighting significant developments since WRAP design began. In an effort to obtain a critical mass of participation in 2027, an Expedited Proposal was developed for a revised transition plan (2024-EP-1) that would expand and extend transition provisions while maintaining Winter 27-28 as the latest possible first binding season for the program. 

2024-NTFP-1 was introduced by WPP to the Program Review Committee (PRC) on June 21st, 2024, to provide changes needed to ensure the Tariff reflected WRAP’s intended design and procedures. Three categories of changes were identified within this request, including changes to:

  1. Correct errors and provide non-substantive clarifying edits;
  2. Ensure the Tariff reflects the original intent of the program design at the time that the Participants were developing the Tariff; and
  3. Revise the Tariff for additional efficiency based on the operating experience to date and review during BPM development.

Both Proposals were approved by the Board of Directors on September 19th, 2024. If approved by FERC, the Expedited Proposal will have an effective date of January 27, 2025.  2024-NTFP-1 will have an effective date of March 16th, 2025 if approved by FERC January 27th, 2025. The changes and corrections from these proposals affect the following governing BPMs:

  • BPM 107 Forward Showing Deficiency Charge
  • BPM 109 Forward Showing Transition Period
  • BPM 206 Settlement Pricing
  • BPM 210 Operations Program Transition Period
  • BPM 301 Workplan Development and Approval
  • BPM 401 New Participant Onboarding

     


Provide a proposed solution to the issue described:


The following list of proposed corrections (with specific language included in the attached red-lined BPMs) do not provide changes to current intent or policy.

BPM

Description of Correction

Section(s)

Source of Change

107

Minor edits - typos, clarifications, references to definitions (removed definition of ‘Aggregate Capacity Deficiency’)

Definitions

2024-NTFP-1

107

Clarify that a Non-Binding Participant under the Critical Mass concept will not be subject to Deficiency Charges

3.2

2024-EP-1

107

Introduce Critical Mass concept in new section. Participating load volume and Participant threshold for a Subregion below which Participants may participate in a Non-Binding manner: 15 GW of load and 3 Participants for the SWEDE; 20 GW and 3 Participants for Mid-C. Add language indicating Participants in a Subregion without Critical Mass may choose to be Non-Binding for the season(s) where Critical Mass is not achieved. Participants have 30 days to provide notice to WPP if they intend to participate as Non-Binding Participants for that Binding Season after notice is given. Such notice and election will be given for each Binding Season without Critical Mass participation.

7

2024-EP-1

109

Extend Transition Period to the Binding Seasons from June 1, 2025, through March 15, 2029 (previously 2028)

1, 2, 3.1, 5.2, 5.3

2024-EP-1

109

Clarify that the Binding Season beginning November 1, 2027, will be the default first Binding Season for all Participants with a WRAPA effective by September 15, 2026

1, 3.1

2024-EP-1

109

Enable Participants to elect to participate in Summer 2027 season as Binding Participants as late as January 15, 2026 (previously two-year notice required by May 31, 2025)

3.2

2024-EP-1

109

Remove reference to priority tiers for access to voluntary assistance during the Transition Period for Binding Participants.

4

2024-EP-1

109

Minor edits - typos, clarifications, references to definitions

5, 5.2, 5.3, 6

2024-EP-1

109

Change Excused Transition Deficit limits to 200% FSPRM (in MW) for Summer 27 and Winter 27-28, and 100% PRM for Summer 28 and Winter 28-29.

5.2

2024-EP-1

109

Set Discounted Deficiency Charge equivalent to: 75% reduction of FS Deficiency Charge during Summer 27 and Winter 27-28; and 50% reduction during Summer 28 and Winter 28-29.

5.2

2024-EP-1

 

 

 

 

109

Appendix A – Senior Official Attestation – ETD language updated to enable signature by a 3rd party

5.1, Appendix A

2024-EP-1

206

Correct the Energy Declined Settlement price to be the Applicable Real-time Index Price for the hour

4.3

2024-NTFP-1

206

Correct the Make Whole Adjustment formula to be the maximum of zero or the result of the current formula

4.5

2024-NTFP-1

206

Minor edits and corrections - typos, clarifications, references to definitions, language conformity

1.4, 2, 4, 4.2, 4.4, 4.8

2024-NTFP-1

210

Extend Transition Period to the Binding Seasons within the time period from June 1, 2025, through March 15, 2029 (previously 2028)

2

2024-EP-1

210

Minor edits and corrections - typos, clarifications, references to definitions (removed definitions of ‘Central Hub’, ‘Tier Three’, and ‘Voluntary Holdback’)

1.4, 2, 3

2024-NTFP-1, 2024-EP-1

210

Remove reference to priority tiers for access to mandatory Holdback during the Transition Period for Binding Participants

3, 4, 5

2024-EP-1

210

Two-tiered access to Voluntary Holdback during the Transition Period. Binding ("Tier One") and Non-Binding ("Tier Two"). Clarify that Non-Binding Participants are only able to access Voluntary Holdback (no Holdback Capacity as a result of surplus Sharing Calculation Results).

4,5

2024-EP-1

210

Update language in BPM to ensure there are enduring provision for Non-Binding Participation due to Critical Mass concept after the Transition Period

1, 1.2, 1.3, 2, 4, 5

 

210, 109

Change title of BPM to “Binding and Non-Binding Participation in Operations Program” and all references to the BPM 210 title in other BPMs

109: 1, 4.1

210: throughout

2024-EP-1

301

Minor corrections – language conformity, alignment with formalized Change Request Form

1.1, 1.4, 4.1

-

301

Correct Change Request and Workplan Development Timeline to accurately reflect Quarterly meeting schedule of the Board of Directors

3

-

401

Minor edits – language conformity

1.4

-

401

Clarify that the Binding Season beginning November 1, 2027, will be the default first Binding Season for all Participants with a WRAPA effective by September 15, 2026

2.1

2024-EP-1

401

Include reference to Non-Binding option should a Subregion not achieve Critical Mass

2.1

2024-EP-1


Provide the specific document and language you would like changed:


Redlined BPM edits are included as an attachment to this Change Request Form. See Description of Correction column for summaries of changes.


Provide a suggestion for how language could be updated to address issue:


Redlined BPM edits are included as an attachment to this Change Request Form. See Description of Correction column for summaries of changes.


File 01 - Description


Download File

Describe the benefits that will be realized from this change


The corrections to the BPMs will ensure alignment with intended policy.


Any data/information that would characterize the importance of the issue:


The BPMs indicated require a series of corrections to erroneous language to align with recent FERC 205 filings. See submissions below:

Name

2024-EP-1

Description

§205(d) Rate Filing:  Tariff Revisions to Adopt a Revised Transition to a Binding Program to be effective 1/27/2025.

Accession Number

20241125-5207 

 

 

Name

2024-NTFP-1

Description

§205(d) Rate Filing:  Revisions to Western Resource Adequacy Program Tariff to be effective 1/27/2025. 

Accession Number

20241127-5309


File 02 - Benefits


-

A flag as a Non-Task Force Proposal indicates the Concept could be implemented without requiring further development into a Proposal by a Task Force. Please check the box if you would like this to be considered as a Non-Task Force Proposal.

Created on Jan. 8, 2025, 3:38 p.m.

Last modified Jan. 27, 2025, 8:59 a.m.