2026-EP-06 (Rockies FS Deadline)

In June, WPP filed a waiver with FERC requesting flexibility to establish FSPRMs for the new Rockies Subregion later than the standard deadlines established in the WRAP Tariff. The waiver was intended to address the timing challenge associated with creating a new Subregion for Participants joining from Colorado. At the time, the applicable FSPRM deadlines occurred, there were no Rockies Participants and, therefore, the Rockies Subregion had not been studied and FSPRMs had not been established. WPP now has two Participants in Colorado, with others intending to join, but does not have a means under the current Tariff timelines to establish the necessary metrics for those Participants. 

Significant progress has been made on Rockies implementation since the waiver was filed in June. SPP was able to develop FSPRMs and other metrics for the new Subregion well in advance of the anticipated deadlines included in the waiver request for the Winter 2027-2028 Binding Season. In addition, WRAP stakeholders have reached consensus on proposals related to Forward Showing Deficiency Charge deferrals for the Rockies Subregion that recognize the unique circumstances associated with onboarding a new Subregion, including additional discounts for qualifying deferrals. 

FERC denied the waiver request on September 21. Yet, WPP and WRAP still need a path to establish the necessary metrics and enable participation by the two new Rockies Participants, as well as other entities intending to join the Subregion. WPP now proposes addressing the issue through a Section 205 filing to amend the WRAP Tariff, supported by an Expedited Proposal to be considered by the RAPC and Board during the week of September 28.