July 1, 2026

Western Power Pool 

Western Resource Adequacy Program 

ELCC + QCC Task Force 

Submitted Via Comments Portal

Re:  Proposal to establish Qualifying Capacity Contribution (QCC) values for new Long-Duration Storage resources that do not fit into an existing resource class 

The undersigned companies appreciate the opportunity to comment on the Proposal to Establish Qualifying Capacity Contribution (QCC) Values for New Long-Duration Storage Resources that Do Not Fit Into an Existing Resource Class, published at https://www.westernpowerpool.org/private-media/documents/PRC_2025_Workplan_-_LDS_QCC_Task_Force_Proposal_-_2026-06-02.pdf 

The proposal appears to be a straightforward and useful way to resolve the issue that Form Energy identified to the Western Resource Adequacy Program (WRAP), and which the WRAP prioritized, around the need to resolve ambiguities in the WRAP about how a participant could establish the Qualifying Capacity Contribution (QCC) of long-duration energy storage (LDES) systems.  That issue arose because those systems may be different from any other resource already accredited under WRAP, and therefore it was unclear how a WRAP participant could establish the necessary data for QCC purposes for those resources with reference to “class average data for resources of similar size.”  (See Business Practice Manual (BPM) 105, p. 19).  

The proposal developed by the ELCC + QCC Task Force would resolve this issue by allowing WRAP participants to develop “synthesized data” for LDES resources that would be used to establish QCC and outage information, and then have that data be replaced, over time, by actual operational data.  The proposal would allow data to be synthesized by reference to engineering or other appropriate data provided by equipment providers and manufacturers of LDES technologies, and submitted by participating utilities to WRAP.  And, it would weigh actual operational data more heavily than synthesized data over time, until the data for LDES resources is based fully on operational data.  

This proposal allows a pathway for participating utilities to establish the value of LDES facilities that they may procure for purposes of WRAP compliance, and also gives needed transparency to the process that will be used to accredit LDES resources that may be different from any other resources already accredited under WRAP.  For these reasons, the proposal is a valuable and straightforward way of addressing the ambiguity that existed in the BPM, and will help provide a smoother pathway for the deployment of LDES resources that are critical to maintaining resource adequacy in the West.  

The undersigned companies support the proposal, and urge its adoption into the WRAP.

/s/ Mark Thompson

Senior Director, State Affairs

Form Energy

/s/ Aric Saunders 

Executive Vice President, Commercialization

Noon Energy

/s/ Christen Blum

Executive Vice President, Commercialization

Fourth Power

/s/ James Larsen 

Chief Executive Officer

e-Zinc

/s/ Gabe Murtaugh

Director, Regulatory Affairs, Western U.S.

Hydrostor

/s/ Jessie Ciulla Shea

Director of Policy & Market Strategy

Energy Dome