Change Request 2026-CRF-002

Business Practice Manual (BPM) 105 Forward Showing Qualifying Resources – Current language states that Participants must complete Operational Tests during the 12-Month period prior to the FS Submittal due date. Participants should be permitted to complete Operational Tests up to the end of the Cure Period to allow them to cure an identified deficiency related to an Operational Test.  

BPM 202 Participant Sharing Calculation Inputs – Language in Section 5.1 Load Forecast requires clarification to ensure the Load Forecast data being submitted in the Operations Program is based on the same load that was submitted in a Participant’s corresponding Forward Showing.  

2026-NTFP-02 modifies two WRAP BPMs (BPM 105 and BPM 202) as detailed below: 

BPM 105 Forward Showing Qualifying Resources – Language in Section 3.4.1, Section 3.4.3.1 and Section 3.4.3.2 has been expanded to allow Operational Testing to be completed through the end of the Cure Period. 

BPM 202 Participant Sharing Calculation Inputs – Language in Section 5.1 has been modified to clarify that the Load Forecast submitted by Participants in the Operations Program shall be based on the same load that was submitted in the Participant’s Forward Showing. 

BPM 105 Language Change (New wording is in bold, and text to be removed is shown with strikethrough):

3.4.1 Background 

Qualifying Resources must have Capability Tests and Operational Tests performed and provided by the Participant, as applicable and in accordance with the guidelines contained in BPM 105. Capability Tests will be required for resources as detailed below. All Qualifying Resources must perform annual Operational Tests completed in the 12-Month period prior to the FS Submittal due date that may be conducted within or outside of a Binding Season (at Participant’s discretion). 

3.4.3 Operational Testing 

All Qualifying Resources must perform annual Operational Tests completed in the 12-Month period prior to the FS Submittal due date, or within the Cure Period, that may be conducted within or outside of a Binding Season (at Participant’s discretion). 

3.4.2  3.4.3.1 Thermal Resources and Long Duration Storage 

An Operational Test serves as an annual demonstration of the functional capability of a Qualifying Resource to generate at a high-level of its Net Generating Capability in the upcoming Binding Season. This test must be completed in the 12-Month period prior to the FS Submittal due date and can be conducted within or outside of a Binding Season (at Participant’s discretion). Test data shall be compiled and submitted via the FS Submittal process, as outlined in BPM 108 Forward Showing Submittal. The Operational Test must be conducted at a minimum of 90% of the Summer Net Generating Capability. The Operational Test shall be conducted for a minimum of one hour, and for Thermal Resources there are no Rated Ambient Temperature requirements for Operational Tests. Any hour with the unit operating at or above 90% of the Net Generating Capability may be deemed a successful Operational Test. In case of failure to meet 90% of the Net Generating Capability, the resource can only claim what it can achieve on the Operational Test (to which the UCAP calculations are applied – see Section 4.2) for purposes of determining its QCC for the upcoming FS Submittal. 

3.4.2 3.4.3.2 Storage Hydro Resources 

An Operational Test serves as a verification that the resource can meet its QCC values on a plant-level basis as determined by the Storage Hydro QCC methodology. This test must be completed in the 12-Month period directly prior to the FS Submittal due date and can be conducted within or outside a Binding Season (at Participant’s discretion). Test data shall be compiled and submitted via the FS Submittal process, as outlined in BPM 108 Forward Showing Submittal. The Operational Test must achieve a minimum of 90% of the plant’s highest monthly QCC value from the FS Submittal being submitted. The Operational Test shall be conducted for a minimum of one hour and there are no Rated Ambient Temperature requirements for Operational Tests. Any hour with the plant operating at or above 90% of the highest monthly QCC submitted for the current and previous Binding Season may be deemed a successful Operational Test. In case of failure to meet 90% of the highest monthly QCC, the resource can claim no more than what it achieved on the Operational Test for purposes of determining its QCC for the upcoming FS Submittal. 

Given that the Operational Test can be performed on any hour in a 12-Month period, the Operational Test should be scheduled (or re-scheduled) for a time when outages/de-rates are not occurring. If one or more units were on outage or de-rated at the time of the Operational Test, in order to claim the full QCC value provided by the Storage Hydro QCC methodology, the Participant shall: 

1. Demonstrate that the unit(s) out/de-rated at the time of the Operational Test were offline/de-rated for more than 90 consecutive days of the 12 Months preceding the FS Submittal due date. 
2. Demonstrate that the unit was out/de-rated for the entirety of one of the Months with the three highest monthly QCC values for the plant. 
3. Provide operational data demonstrating the unit(s) performance on any hour within the 12 Months preceding the FS Submittal due date, or within the Cure Period. 
4. Add the sustained hour-long operational value from the hour identified in (3) to the Operational Test values. 

If 90% of the highest monthly QCC value cannot be achieved after this addition, the Participant can claim no more than the Operational Test (after the addition in (4) above) for any Month's QCC value. 

BPM 202 Language Change (New wording is in bold, and text to be removed is shown with strikethrough): 

5.1 Load Forecast 

The Load Forecast is the Participant’s hourly forecast of its WRAP load, expressed in MW, submitted for each operating hour. The data submitted for Load Forecasts shall account for the total load/demand the Participant is responsible for serving under WRAP and be based on the sourced from the  same  data load /demand that was utilized in the FS Submittal. If there are additional third-party loads or excluded loads within a Participant’s Balancing Authority Area (BAA), these shall not be accounted for in the Load Forecasts submitted in the Operations Program. 

See above. 

The changes in BPM 105 Forward Showing Qualifying Resources will provide WRAP Participants with additional time to complete Operational Tests.  

The changes in BPM 202 Participant Sharing Calculation Inputs provide WRAP Participants with clarity on the load forecasting requirements in the Operations Program.   

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