Change Request 2026-CRF-003

Business Practice Manual (BPM) 106 Qualifying Contracts describes how a contract may be able to receive Qualifying Capacity Contribution (QCC) towards a Participant’s Forward Showing (FS) Capacity Requirement and explains when a Joint Contract Accreditation Form (JCAF) is required to ensure contractual resources are not double counted. The Proposed changes to BPM 106 in this NTFP would: 

1. Reduce the administrative burden involved with verifying contracts between Participants via JCAFs by removing the JCAF and signature requirement for Participant-to-Participant transactions; and  
2. Allow a WRAP Participant and its customer whose load is served through a contract with an entity that is not the WRAP Participant (“Embedded Load Customer”) to agree to the WRAP Participant’s use of the customer’s loads and resources in its FS Demonstration. 

Participant-to-Participant JCAFs

BPM 106 currently requires JCAFs to be: (a) signed by both buyer and seller for Resource Specific Capacity Agreements and/or Systems Sales between WRAP Participants, and (b) submitted by the Participant buyer as part of its Forward Showing (FS) Demonstration. Under the proposed solution, the contents of the JCAF would instead be populated by the Participant buyer in the Forward Showing software system, and acknowledged by both Participant buyer and Participant seller as part of their FS Demonstrations The FS Demonstration would also include an acknowledgement of WRAP Qualifying Transmission, removing the need for the seller to sign the current transmission attestation in BPM 106 Appendix A (see Section 4).

Embedded Load Customers

A WRAP Participant may have a customer (new definition: “Embedded Load Customer”) whose load is served through a contract (new definition: “Embedded Load Qualifying Contract”) with an entity that is not the WRAP Participant. This NTFP would allow such a WRAP Participant to agree with its Embedded Load Customer to use the latter’s loads and resources in its FS Demonstration (new definition: “Embedded Load Acknowledgement and Resource Assurance Agreement”). A Participant including an Embedded Load Qualifying Contract in its FS Demonstration via an Embedded Load Acknowledgement and Resource Assurance Agreement would also require a JCAF with the seller to the Embedded Load Customer.

Changes made to:

•  BPM 106 Qualifying Contracts
• Joint Contract Accreditation Form
• Embedded Load Assurance Agreement

Discussing at 6/10 PRC meeting. 

N/A

Participant-to-Participant JCAFs

Removing the requirement for JCAFs and JCAF signatures between Participants will significantly reduce the administrative burden on Participants and could also lead to reduced FS Deficiencies.

Embedded Load Customers

This NTFP would allow a Participant and its Embedded Load Customer to acknowledge and agree that, solely for the purposes of the WRAP, the former can include the latter’s load and resources or contracts as part of its FS Demonstration.

WRAP Participants have strongly advocated for the removal of the seller signature requirement on Participant-to-Participant JCAFs. As such, WPP proposes to reduce the administrative burden by removing the JCAF and requisite JCAF signature requirement for transactions between Participants. Participant-to-Participant transaction evidencing will instead be moved to the Forward Showing software system.