Change Request 2025-CRF-004

Section 16.3 (Transmission Exceptions) – This section implicitly acknowledges that a lack of ability to procure firm transmission in the forward showing timeframe is often not possible at this time, which clearly indicates Firm Transmission is not ready at this time to be included in the RA program’s Forward Showing.  In short, the FS Transmission Requirement subjects individual LSEs to RA penalty risk because of inadequate regional transmission planning.

Transmission planning does not belong intertwined with RA.        

Additionally, the penalties applied in the case of a deficiency solely related to the FS Transmission Requirement are based on the Cost-of-New Entry for a gas-fired power plant and are thus not based on the cause of issue, which is solely related to inability to procure firm transmission. If penalties were to apply for a deficiency in procuring firm transmission, the penalties should be based on the transmission provider’s cost of the transmission under its OATT. 

This NTFP proposes to change Section 16 to implement a transition period– during which the FS Transmission Requirement will not apply.  The transition period would end when there is a demonstrated ability to procure firm transmission in the forward showing timeframe consistent with the requirements of Section 16. 

Alternatively, this NTFP proposes modification to the deficiency penalties that apply in the circumstance of deficiency solely related to the FS Transmission Requirement. The proposal is to change/bifurcate the deficiency penalties such that the existing CONE-based penalties would apply in the case of deficiency in the FS Capacity Requirement, but an OATT-based transmission penalty would apply in the case of a deficiency solely related to the FS Transmission Requirement. This is reasonable because the LSE should not be penalized with a cost of procuring a capacity resource if it in fact has procured the applicable capacity resource and lacks only the firm or conditional firm transmission at the time of the forward showing.

WRAP Tariff and associated BPMs including MTEC (Monthly Transmission Exception Check)

16.3 FS Transmission Requirement

16.3.2.1 Enduring Constraints. 

16.3.2.2 Future Firm ATC Expected. 

16.3.2.3 Transmission Outages and Derates. 

16.3.2.4 Counterflow of a Qualifying Resource. 

17.3 Transition Period, Deficiency Charges 

Leverage the work done to develop Section 16 to be a transitional milestone, not a list of exceptions that are difficult to manage and provide and do nothing to solve the region’s deliverability problem.

Section 16 – Deliverability/75% FT requirement is delayed until WPP/SPP can provide that the consistent need for the exceptions no longer exists – for X month/Binding seasons – there was FT available on OASIS for the paths and duration needed for compliance. Until then, there are no penalties for FT – just QCC.

1. Incent participants to make the effort by penalizing the BPA FT tariff rate for any transmission deficiency – participants would have to pay twice if they use non-compliance transmission but would be rebated or not pay the penalty.

Excused Transition Deficit – all FS Transmission penalties excused until proven that all of the Section 16 Exceptions have been shown to have been resolved

• OASIS does show FT on the desired paths at time of FS
• Bulletin board developed for this purpose does not show FT on the desired paths at FS
• Ref Section 16.3 – Transmission Exceptions
• Or penalties for a deficiency solely related to the FS Transmission Requirement are changed to the firm transmission rates as published on OASIS.  BPA’s OATT long-term-firm point-to-point rates would be reasonable for the Northwest Region; another transmission providers’ rates may be justified in other regions.
• Penalties as described in Section 17 Apply to deficiencies for FS Capacity Requirement

This would allow the WRAP program to focus on Resource Adequacy and not get intermingled with transmission planning. The incentives would be lined up and the program would be able to go binding and meet its purpose.

WRAP’s FS Capacity Requirement for QCC makes a lot of sense. The WRAP operators (WPP) can readily validate if its participants have supply QCC (qualified by capacity tests) that meets load and planning reserve, with the load also being validated with load forecasts based on historical loads and weather and growth trends. 

If a participant is deficient and there really is no one else in the WRAP participants pool that has excess, then there really is a capacity deficiency. 

The current “deliverability” component  is where WRAP Design (Phase 2) fails, at least at this time. This needs to be remedied or Calpine and probably others will need to exit the program, and probably delay the implementation of the program even further.