Change Request 2025-CRF-017

Bonneville views this CRF as part of the ongoing discussion regarding the RAPC resolution to reform Forward Showing charges and the definition of commercially reasonable efforts. The goal of this CRF is to ensure that this discussion is held at the PRC level (via the PRC change process) as well as at the RAPC.

The discussion on Forward Showing charges should include exploring the option to waive charges if commercially reasonable efforts have been made because:

1. Deferring the CONE penalty or partial CONE payment if commercially reasonable efforts have been demonstrated deters broad participation in the Program. The CONE penalty does nothing to resolve physical constraints or other factors that may have prevented a participant from meeting Forward Showing obligations despite commercially reasonable efforts.  
2. Charges should be applied to situations of negligence or nefarious intent rather than situations where a participant attempted to meet the obligations but failed due to external constraints.

Waive all CONE charges/payments if commercially reasonable efforts have been made and demonstrated.

Will likely drive broader and more sustained WRAP membership.