Please supply any comments related to the proposed changes in BPM 104 - Capacity Critical Hours
No response submitted.
Please supply any comments related to the proposed changes in BPM 108 - Forward Showing Submittal Process
No response submitted.
Please supply any comments related to the proposed changes in the WRAP Tariff
No response submitted.
General Comment
Dear Western Power Pool Board:
The Committee of State Representatives (COSR) appreciates the ongoing efforts of WPP staff and stakeholders to enhance the WRAP program and strengthen its reliability framework. COSR understands that the proposed Capacity Critical Hours (CCH) by Subregion methodology is intended to address the limitations of applying a single set of critical hours across an increasingly diverse and geographically expansive WRAP footprint. By determining CCH at the subregional level, the proposal should result in modeling that better reflects localized reliability conditions, transmission constraints, and the realities of capacity availability across the region. COSR generally supports this approach, which appears to better align the CCH methodology with other elements of WRAP's planning and reliability framework that already recognize geographic and transfer capability limitations.
COSR encourages consideration of this proposal within the broader context of ongoing WRAP accreditation reforms, including forthcoming changes to the Effective Load Carrying Capability (ELCC) methodology currently under development. The selection of CCH is a foundational input to resource accreditation, and changes to CCH determination can materially affect the accredited value of resources across technologies, locations, and operating profiles. While improved modeling accuracy is the stated objective of the proposal, changes to CCH selection can have significant impacts on resource accreditation outcomes. As WRAP evaluates multiple proposals related to accreditation reforms in parallel, it is important to recognize the combined effects and promote results that are transparent, predictable, and consistent with the program's reliability objectives.
Finally, COSR encourages WPP to work with stakeholders to provide greater clarity on what will be defined by the proposed "Additional Adjustments" framework. As drafted, the term is defined to broadly to capture regional interchange, scarcity conditions and pricing, and other factors that may materially influence the selection of CCH. While the proposal appears to intentionally adopt a more flexible and less prescriptive approach, COSR encourages WPP to provide greater clarity on how future changes to the framework (and its underlying assumptions) will be developed and communicated to stakeholders, given the term’s important impact on calculating CCH.
COSR appreciates the substantial work undertaken to develop this proposal and generally supports efforts to improve the accuracy and regional representativeness of WRAP reliability assessments through the proposed subregional CCH framework. We look forward to continued engagement in the review of ongoing program enhancements.
Thank you for your consideration of these comments.
Respectfully,
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
Arizona, Nick Myers, Chairman, Arizona Corporation Commission
Nevada, Tammy Cordova, Commissioner, Nevada Public Utilities Commission
California, Darcie Houck, Commissioner, California Public Utilities Commission
New Mexico, Pat O'Connell, Commissioner, New Mexico Public Regulation Commission
Colorado, Eric Blank, Chair, Colorado Public Utilities Commission
Oregon, Letha Tawney, Chair, Oregon Public Utility Commission
Idaho, Dayn Hardie, Commissioner, Idaho Public Utilities Commission
Wyoming, Chris Petrie, Deputy Chairman, Wyoming Public Service Commission
Submitted Responses
2026-EP-05 (CCH By Subregion)
Please supply any comments related to the proposed changes in BPM 104 - Capacity Critical Hours
Please supply any comments related to the proposed changes in BPM 108 - Forward Showing Submittal Process
Please supply any comments related to the proposed changes in the WRAP Tariff
General Comment
Dear Western Power Pool Board:
The Committee of State Representatives (COSR) appreciates the ongoing efforts of WPP staff and stakeholders to enhance the WRAP program and strengthen its reliability framework. COSR understands that the proposed Capacity Critical Hours (CCH) by Subregion methodology is intended to address the limitations of applying a single set of critical hours across an increasingly diverse and geographically expansive WRAP footprint. By determining CCH at the subregional level, the proposal should result in modeling that better reflects localized reliability conditions, transmission constraints, and the realities of capacity availability across the region. COSR generally supports this approach, which appears to better align the CCH methodology with other elements of WRAP's planning and reliability framework that already recognize geographic and transfer capability limitations.
COSR encourages consideration of this proposal within the broader context of ongoing WRAP accreditation reforms, including forthcoming changes to the Effective Load Carrying Capability (ELCC) methodology currently under development. The selection of CCH is a foundational input to resource accreditation, and changes to CCH determination can materially affect the accredited value of resources across technologies, locations, and operating profiles. While improved modeling accuracy is the stated objective of the proposal, changes to CCH selection can have significant impacts on resource accreditation outcomes. As WRAP evaluates multiple proposals related to accreditation reforms in parallel, it is important to recognize the combined effects and promote results that are transparent, predictable, and consistent with the program's reliability objectives.
Finally, COSR encourages WPP to work with stakeholders to provide greater clarity on what will be defined by the proposed "Additional Adjustments" framework. As drafted, the term is defined to broadly to capture regional interchange, scarcity conditions and pricing, and other factors that may materially influence the selection of CCH. While the proposal appears to intentionally adopt a more flexible and less prescriptive approach, COSR encourages WPP to provide greater clarity on how future changes to the framework (and its underlying assumptions) will be developed and communicated to stakeholders, given the term’s important impact on calculating CCH.
COSR appreciates the substantial work undertaken to develop this proposal and generally supports efforts to improve the accuracy and regional representativeness of WRAP reliability assessments through the proposed subregional CCH framework. We look forward to continued engagement in the review of ongoing program enhancements.
Thank you for your consideration of these comments.
Respectfully,
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
Arizona, Nick Myers, Chairman, Arizona Corporation Commission
Nevada, Tammy Cordova, Commissioner, Nevada Public Utilities Commission
California, Darcie Houck, Commissioner, California Public Utilities Commission
New Mexico, Pat O'Connell, Commissioner, New Mexico Public Regulation Commission
Colorado, Eric Blank, Chair, Colorado Public Utilities Commission
Oregon, Letha Tawney, Chair, Oregon Public Utility Commission
Idaho, Dayn Hardie, Commissioner, Idaho Public Utilities Commission
Wyoming, Chris Petrie, Deputy Chairman, Wyoming Public Service Commission