To: WRAP Program Review Committee

From: Committee of State Representatives – Leadership

Date: June 15, 2026

RE: COSR Comment on the Demand Response Qualifying Capacity Contribution Task Force Proposal

Dear Program Review Committee Members:

Thank you for the opportunity for the Committee of State Representatives (COSR) to review the draft proposal for a new Demand Response (DR) Qualifying Capacity Contribution (QCC) methodology. Demand response programs vary significantly across the Western Resource Adequacy Program (WRAP) footprint. States in the West operate under diverse regulatory frameworks and policy objectives for demand-side resources, resulting in a patchwork of distinct DR programs administered by utilities, balancing authorities, and market operators. WRAP Participants have recognized that the initial Tariff language describing the use of DR as a Capacity Resource in the Forward Showing does not fully account for important operational constraints, including use limitations, program fatigue, call-frequency limits, and other factors that may affect resource availability.

We recognize that these concerns were initially identified in the 2025-2026 PRC Work Plan, and that, following over nine months of stakeholder deliberation, acknowledges the hard work of task force members in developing this proposal. In particular, the establishment of a standardized workbook that captures the wide array of DR program constraints will be particularly useful. This workbook, paired with the proposed updated testing methodology, represents a thoughtful and structured approach to improving accuracy and transparency in reflecting how DR is accounted for in the Forward Showing.

In the context of a regional reliability program, the WRAP is responsible for establishing standardized frameworks that accurately represent resource performance in the Forward Showing. This proposal represents a positive step toward achieving that objective by incorporating an approach that captures the distinct characteristics, operational constraints, and performance variability of different DR programs, ensuring they are evaluated consistently and credibly alongside other resource categories.

Committee members were provided with an overview of this proposal by Western Power Pool (WPP) staff on May 22, 2026, followed by an opportunity to identify specific concerns or feedback. No such concerns were raised. We appreciate the continued efforts of WPP staff and WRAP participants to refine and improve various elements of the WRAP.

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