Submitted Responses
COSR Comment on 2026-NTFP-04
Please supply any comments related to the proposed changes in BPM 202 - Section 7.2 Operating Day File
General Comment
No general comment submitted.
Submitted Responses
Please supply any comments related to the proposed changes in BPM 202 - Section 7.2 Operating Day File
General Comment
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 agree with the intent of WPP’s proposal to modify the Business Practice Manual (BPM) 202 with added detail describing how Multi-Day (MD) and Operating Day (OD) files are used in the Operations Program Sharing Calculation. The proposed revisions also provide added transparency for participants, with language that explains the logic applied when the Operations Client processes both MD and OD files.
We welcome continued enhancements to the BPM so that language accurately reflects the latest operational practices and system functionality.
We appreciate the continued efforts to refine and strengthen the program.
Resectfully,
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