To: WRAP Program Review Committee

From: Committee of State Representatives – Leadership

Date: July 20, 2026

RE: COSR Comment on 2026-NTFP-05: Clarification of FS Deficiency Charges & FS Deadline Extension Due to FS Software Failures

Dear Program Review Committee Members:

Thank you for the opportunity for the Committee of State Representatives (COSR) to review the Non-Task Force Proposal (NTFP) introduced and sponsored by the Western Power Pool (WPP). Recognizing that this proposal is limited to specific implementation provisions that directly impact Western Resource Adequacy Program (WRAP) Participants, the COSR will not be providing formal comments on behalf of the full committee. However, committee members were made aware of this NTFP during their monthly meeting on June 24 with an opportunity to provide feedback or express concerns during the COSR comment period. No such comments were received.

We acknowledge the benefits of modifying both the Tariff and Business Practice Manual (BPM) 107 with added guidance to address cases where there is both a Non-Binding Season and a Binding Season in a single Forward Showing (FS) Year. WPP’s proposal to zero out the Monthly FS Deficiency Charges for a Non-Binding Summer Season preceding the first Binding Winter Sinding Season will address potential gaming opportunities for participants to artificially inflate the Non-Binding Summer Season’s FS Deficiency to minimize the following Winter Season’s FS Deficiency Charge.

Similarly, we support WPP’s addition of language in the Tariff and BPM 108 to establish a process for addressing instances in which participants are unable to make FS or Cure Period submissions due to a software system outage.

We welcome continued enhancements to the BPM with the intent of offering additional clarity and guidance for WRAP Participants.

We appreciate the continued efforts to refine and strengthen the program.

 Respectfully,

Chris Parker

Chair, Committee of State Representatives

Director, Utah Division of Public Utilities

Brian Rybarik

Vice Chair, Committee of State Representatives

Chair, Washington Utilities and Transportation Commission