Please supply any comments related to the proposed changes in BPM 109 - Forward Showing Transition
No response submitted.
Please supply any comments related to the proposed changes in BPM 210 - Binding and Non-Binding Participation in Operations Program
No response submitted.
Please supply any comments related to the proposed changes in the WRAP Tariff
No response submitted.
General Comment
Bonneville appreciates the opportunity to provide comments on the Deficiency Charge Deferral resolution. Bonneville strongly supports this resolution as a short-term solution and the proposal’s underlying intent as a practical, transitional mechanism to help participants navigate rapid load growth, supply chain disruptions, and capacity acquisition challenges as we move toward a binding program. Bonneville commends WPP, the RAPC, and all others who contributed to this proposal for designing a balanced approach that encourages proactive resource procurement and sustained program participation without imposing unintended barriers during this critical onboarding phase.
While Bonneville supports this proposal as an effective near-term bridge, we view several aspects of this proposal as transitional rather than as part of an enduring long-term design. It is very important that WRAP develop a long-term solution to this issue soon. To ensure a durable and thoroughly vetted framework for the future, Bonneville requests that the Program Review Committee (PRC) formally incorporate the development of a permanent deficiency charge deferral structure into this year’s workplan, so that the program can begin working on a permanent solution to this issue through an open public process. Bonneville would like to see the following in a long term charge deferral solution:
A participant should only be able to point to a specific resource that was expected to be available by the season in which they were deficient and the delay of that resource caused the failure to meet the requirement.
Deferral amounts will need to be reviewed to ensure participants are planning to meet loads with physical resource when they materialize, not years later.
Ensuring that resource acquisition is the requirement for meeting deferral requirements, and that simply load loss does not create a path to meeting the requirements of a deferral.
Finally, because this pragmatic approach of having a short-term and long-term solution, offers an effective pathway for addressing both capacity and transmission scarcity, Bonneville encourages WPP to apply this same constructive structure to resolve other outstanding issues currently obstructing the program’s readiness for binding operations.
Submitted Responses
2026-EP-03 (Deficiency Charge Deferral)
Please supply any comments related to the proposed changes in BPM 109 - Forward Showing Transition
Please supply any comments related to the proposed changes in BPM 210 - Binding and Non-Binding Participation in Operations Program
Please supply any comments related to the proposed changes in the WRAP Tariff
General Comment
Bonneville appreciates the opportunity to provide comments on the Deficiency Charge Deferral resolution. Bonneville strongly supports this resolution as a short-term solution and the proposal’s underlying intent as a practical, transitional mechanism to help participants navigate rapid load growth, supply chain disruptions, and capacity acquisition challenges as we move toward a binding program. Bonneville commends WPP, the RAPC, and all others who contributed to this proposal for designing a balanced approach that encourages proactive resource procurement and sustained program participation without imposing unintended barriers during this critical onboarding phase.
While Bonneville supports this proposal as an effective near-term bridge, we view several aspects of this proposal as transitional rather than as part of an enduring long-term design. It is very important that WRAP develop a long-term solution to this issue soon. To ensure a durable and thoroughly vetted framework for the future, Bonneville requests that the Program Review Committee (PRC) formally incorporate the development of a permanent deficiency charge deferral structure into this year’s workplan, so that the program can begin working on a permanent solution to this issue through an open public process. Bonneville would like to see the following in a long term charge deferral solution:
A participant should only be able to point to a specific resource that was expected to be available by the season in which they were deficient and the delay of that resource caused the failure to meet the requirement.
Deferral amounts will need to be reviewed to ensure participants are planning to meet loads with physical resource when they materialize, not years later.
Ensuring that resource acquisition is the requirement for meeting deferral requirements, and that simply load loss does not create a path to meeting the requirements of a deferral.
Finally, because this pragmatic approach of having a short-term and long-term solution, offers an effective pathway for addressing both capacity and transmission scarcity, Bonneville encourages WPP to apply this same constructive structure to resolve other outstanding issues currently obstructing the program’s readiness for binding operations.