Change Request 2025-CRF-013

Under the current WRAP Business Practice requirements, certain qualifying contracts require a completed and executed Joint Contract Accreditation Form (JCAF) with signatures from both counterparties. This requirement applies even when both counterparties are WRAP participants and the Qualifying Capacity Contribution (QCC) is directly verified and mutually agreed upon within the EDST Forward Showing (FS) portal.

For participant to participant transactions, the JCAF signature requriement duplicates existing verification controls. Both WRAP participants must independently review and agree to the QCC values in EDST, and each participant is already required to certify all FS inputs through a senior executive attestation as part of the Forward Showing process. As a result, the additional requirement to route JCAF's for signature is labor-intensive, time-consuming, and operationally redundant with too many areas for manual error making the form ultimately deficient in the eyes of WRAP if not correct.

This redundancy has become a material compliance issue. The WRAP program has identified a significant number of FS deficiencies (over 400) attributable solely to incomplete, incorrect, or unsigned JCAFs, rather than to disputes over QCC values or underlying contract eligibility.

Allow participant to participant qualifying contracts within the WRAP program to be validated without requiring executed JCAF signatures, provided that:

• Both counterparties are WRAP participants
• The QCC is entered, reviewed, and mutually agreed upon by both parties in the EDST FS portal
• Each participant completed the required Forward Showing executive certification attesting to the accuracy and completeness of its FS inputs.

Under this approach, EDST mutual agreement and executive FS certification would serve as the primary verification mechanism for QCC, eliminating the need for separate JCAF signatures for participant-to-participant transactions.

This change would apply to WRAP Business Practice Manual 106 (Qualifying Contracts), specifically the provisions requiring executed Joint Contract Accreditation Forms for participant to participant qualifying contracts, as well as any related references to signature requirements where QCC is otherwise verified through the EDST Forward Showing process.

Revise BPM 106 to allow participant to participant qualifying contracts to satisfy accreditation requirements through mutual QCC confirmation in the EDST FS portal and completion of the Forward Showing executive certification, without requiring executed JCAF signatures.

The updated language should clarify that JCAF execution remains required where counterparties are non-participants or where EDST mutual verification is not available, while explicitly recognizing EDST agreement and executive FS attestation as sufficient for participant-to-participant transactions.

City Light's FS program experience to date along with other WRAP participant data compiled by WPP and SPP indicate that over 400 Forward Showing deficiencies are attributable to incomplete or unsigned JCAF forms, rather than disagreements over QCC values. Allowing EDST based verification in lieu of JCAF signatures for participant-to-participant transactions would materially reduce administrative burden, improve compliance outcomes, and allow staff and participants to focus on substantive reliability requirements rather than duplicative paperwork.

This change would significantly reduce administrative burden and improve compliance efficiency for WRAP participants by eliminating a duplicative signature requirement for participant-to-participant qualifying contracts. Where both counterparties are WRAP participants, QCC values are already mutually reviewed and agreed upon in the EDST Forward Showing portal, and each participant is required to certify all Forward Showing inputs through a senior executive attestation. Recognizing these existing contracts as sufficient verification removes unnecessary process steps without reducing accountability.

Allowing EDST mutual agreement and executive FS certification to serve in lieu of executed JCAF signatures would streamline the Forward Showing process, reduce delays, and all participants to focus resources on substantive reliability and compliance activities rather than document routing. This change also improves program credibility by aligning documentation requirements with actual risk and control structures already embedded in WRAP.

Program experience to date indicates that a substantial number of Forward Showing deficiencies are attributable solely to incomplete or unsigned JCAF forms, rather than disagreements over QCC values or contract eligibility. The WRAP program has identified over 400 FS deficiencies relation specifically to JCAF completion issues.

These deficiencies create additional administrative workload for participants and program staff and delay resolution of otherwise compliant Forward Showings. Given that EDST already requires mutual counterparty agreement and executive-level certification, the continued reliance on signed JCAFS for participant-to-participant transactions represents a disproportionate process burden relative to the compliance risk being addressed. 

This process made sense when the Forward Showing workbooks were submitted via EXCEL document to SPP and there was no mutual platform for participate to participant inputs like currently available through EDST.