Lead Sponsor's Description of the Issue:
In November 2024, Western Power Pool (WPP) submitted two FERC 205 filings to the Federal Energy Regulatory Commission (FERC) proposing changes to the WRAP Tariff outlined in Proposals 2024-EP-1 and 2024-NTFP-1. The WRAP Business Practice Manuals (BPMs) require a series of corrections in response to updates to Tariff language included in these filings. The timeline of events leading to the changes described in this document is as follows.
On April 22nd, 2024, the Resource Adequacy Participant Committee (RAPC) published a letter to the region reaffirming commitment to the program and highlighting significant developments since WRAP design began. In an effort to obtain a critical mass of participation in 2027, an Expedited Proposal was developed for a revised transition plan (2024-EP-1) that would expand and extend transition provisions while making Winter 27-28 the default first binding season for all WRAP Participants (with the option of going binding earlier in Summer 2027). 2024-EP-1 was made available for comment by the RAPC on August 30th, 2024, and submitted to FERC November 25th, 2024.
2024-NTFP-1 was introduced by WPP to the Program Review Committee (PRC) on June 21st, 2024, to provide changes needed to ensure the Tariff reflected WRAP’s intended design and procedures, and filed with FERC November 27th, 2024. Three categories of changes were identified within this request, including changes to:
- Correct errors and provide non-substantive clarifying edits;
- Ensure the Tariff reflects the original intent of the program design at the time that the Participants were developing the Tariff; and
- Revise the Tariff for additional efficiency based on the operating experience to date and review during BPM development.
FERC approved both filings on January 24th, 2025: the revised transition plan in the Expedited Proposal became effective immediately while the changes in 2024-NTFP-1 have an effective date of March 16th, 2025. The changes and corrections from these proposals affect the following governing BPMs:
- BPM 107 Forward Showing Deficiency Charge
- BPM 109 Forward Showing Transition Period
- BPM 206 Settlement Pricing
- BPM 210 Operations Program Transition Period
- BPM 301 Workplan Development and Approval
- BPM 401 New Participant Onboarding