Request Summary
BPM changes resulting from the Revised Transition Plan (2024-EP-001) and housekeeping
Co-sponsors
Description Of 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:
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:
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Proposed Solution
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 |
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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 |
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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 |
Specific Document And Language
Redlined BPM edits are included as an attachment to this Change Request Form. See Description of Correction column for summaries of changes.
Suggested Language Update
Redlined BPM edits are included as an attachment to this Change Request Form. See Description of Correction column for summaries of changes.
Benefits
The corrections to the BPMs will ensure alignment with intended policy.
Data Or Information
The BPMs indicated require a series of corrections to erroneous language to align with recent FERC 205 filings. See submissions below:
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