JEFF KUGEL | PNGC Power
September 29, 2026
Submitted via the WPP Portal and email.
WPP WRAP Program
c/o Maya McNichol
WRAP Policy and Engagement Manager
Re: PNGC Comments on WRAP BPM 110 - Cost of New Entry (CONE)
The Pacific Northwest Generating Cooperative (PNGC) is offering general comments on the WRAP’s proposed Cost of New Entry (CONE) business practice document BPM 110.
Overall, PNGC is seeking greater clarity in how the CONE was calculated and greater transparency on how the final $ per kW-yr was modeled and derived in BPM 110.
PNGC generally agrees with this Business Practice and the individual components which encompass the CONE calculations. However, there is a considerable gap in detailing what values were used for each variable, whether the values represent the current market conditions, and how the CONE calculation deploys each variable.
As it stands today, BPM 110 only has a list of the variables and definitions of what is represented with each variable. BPM 110 does not specify which generation technology (or technologies) were used and how that translated into the final CONE value. For example, is the CONE price an average or median of a variety of resources, or does it represent a single price for a selected proxy resource determined by WRAP?
PNGC requests the WRAP provide additional details on these calculations so that we can better assess what the CONE represents and how it may impact participants of the program. At a minimum, conveying what values were used for each input and what proxy resources were modeled in the CONE calculations. For consideration, PNGC views the PJM CONE Study1 as an excellent example of a fully developed CONE pricing study. While PNGC does acknowledge the Brattle CONE study was created for a mature market, we do encourage WRAP to move in this direction over time to a comprehensive, rigorous, and detailed CONE study.
Thank you for the opportunity to provide input into the process.
Jeff Kugel
Sr. Director Power Operations and Trading
PNGC Power
CAMILLE CHRISTEN | Idaho Power Company
Idaho Power supports the proposed BPM 110 – Cost of New Entry (CONE). The draft provides a clear and transparent process for calculating, reviewing, and updating the CONE value and appropriately implements the requirements established in the WRAP tariff.
Idaho Power particularly supports the inclusion of a defined annual review process and the documentation of the methodology used to establish CONE values. A transparent and predictable approach is important because CONE serves as a foundational component of the WRAP deficiency charge framework and resource adequacy program. Overall, Idaho Power believes the proposed BPM improves transparency, consistency, and stakeholder understanding of the CONE calculation process and supports approval of BPM 110 – Cost of New Entry (CONE) as proposed.