General Comment

Dear Program Review Committee Members and Western Power Pool Staff,  

Thank you for the opportunity to review the 2024 Non-Task Force Proposal-1 that addresses corrections to the Western Resource Adequacy Program (WRAP) Tariff that was approved by the Federal Energy Regulatory Commission on February 10, 2023.

The Committee of State Representatives (COSR) is generally supportive of the corrections made to the WRAP Tariff to better align the tariff language with intended policy and appreciates the efforts of the Western Power Pool staff to incorporate any further clarifications made during the public comment period. However, the COSR is unsure of the changes made to enable Business Practice Manual (BPM) 103 Forward Showing Capacity Requirement and the demand response options and asks for more clarification on this issue to better understand the comments received. The Tariff addressed two of three demand response options and though WPP and stakeholders attempted to include all options into the NTFP-1 corrections, the difference in commenter opinion on Option Two with the P50 Peak Load Modifier raises some concern. The COSR encourages the PRC and WPP to facilitate a discussion on this issue with all commenters, especially those that wished to remove this option entirely, to foster greater understanding of the issue and any implications of including or excluding this option.

The COSR looks forward to future discussion and engagement with the PRC, WPP, and other stakeholder committees. There is no further comment on 2024 NTFP-1 at this time, and we anticipate more information from WPP and commenters on the issues raised during the public comment period.

Respectfully submitted,

The Committee of State Representatives