Change Request 2025-CRF-012

Under the current WRAP framework, Planning Reserve Margin (PRM) values in shoulder months may be materially higher than those associated with a participant's historically observed seasonal peak load conditions. In certain cases, this results in FS Capacity Requirements that significantly exceed a participant's actual historical peak load for the corresponding season.

Because shoulder months do not consistently coincide with periods of highest reliability risk, elevated PRM values in these months may produce deficiency charges that are disproportionate to a participant's true capacity shortfall risk, even when sufficient resources exist to serve historically observed seasonal peak load.

Establish a limited WRAP exception that allows relief from deficiency charges in designated shoulder months when PRM-driven FS Capacity Requirements materially exceed a participant's historical seasonal peak load.

The exception would be available once per season (Summer or Winter) and applicable to one designated shoulder month per year, subject to defined trigger conditions and verification requirements.

Applicable documents include the WRAP Tariff and any associated WRAP implementation, compliance, or deficiency charge provisions that define FS Capacity Requirements and the assessment of deficiency charges for shoulder months.

And any other documentation that the PRM task force might be currently developing may need specific language added or changed to include this exception.

Add an exception provision allowing a participant to request full or partial relief from the WRAP Deficiency Charge for a designated shoulder month if the calculated FS Capacity Requirement exceeds the participants historically observed seasonal peak load by 12%-18% 

The language should specify:

• Recognized shoulder months (Summer: June, September; Winter: November, March)
• Eligibility limited to one shoulder month per season
• Verification requirements for historical load and PRM data
• Limitations preventing carryover of relief or application where PRM exposure is already mitigated through existing commitments.

This change would provide a narrowly defined mechanism to address anomalous Planning Reserve Margin outcomes in shoulder months while preserving WRAP's core reliability objectives. By allowing limited relief where FS Capacity Requirements materially exceed a participant's historical seasonal peak load, the proposal reduces the risk of disproportionate deficiency charges that are driven by PRM volatility rather than actual capacity shortfall risk.

The exception improves fairness and predictability for participants, supports continued engagement in the program, and enhances confidence that deficiency charges are aligned with real reliability needs. At the same time, the proposed limitations and verification requirements ensure the exception is applied only in well-defined circumstances and does not weaken overall compliance incentives.

Recent WRAP Forward Showings have demonstrated that PRM values in certain shoulder months can be materially higher than those observed during historically higher risk seasonal peak load periods. In these cases, FS Capacity Requirements may exceed a participant's historical seasonal peak load by a meaningful margin, despite no corresponding increase in actual system or load risk.

Although shoulder-month deficiencies may occur infrequently, the financial and policy impacts can be significant when they do occur. Providing a limited exception for these circumstances recognizes the outsized effect of PRM volatility in shoulder months and helps ensure deficiency charges remain proportional to actual reliability risk.