Please supply any comments related to Section 1. Introduction.
No response submitted.
Please supply any comments related to Section 2. Background sections
No response submitted.
Please supply any comments relatedto Section 3. Calculation of CONE
No response submitted.
Please supply any comments related to Section 4. Methodology
No response submitted.
Please supply any comments related to Section 5. Annual Review of CONE
No response submitted.
Please supply any comments related to Section 6. Changes in CONE
No response submitted.
Please supply any comments related to Section 7. Current CONE Value
No response submitted.
General Comment
September 29, 2026
Submitted via the WPP Portal and email.
WPP WRAP Program
c/o Maya McNichol
WRAP Policy and Engagement Manager
Re: PNGC Comments on WRAP BPM 110 - Cost of New Entry (CONE)
The Pacific Northwest Generating Cooperative (PNGC) is offering general comments on the WRAP’s proposed Cost of New Entry (CONE) business practice document BPM 110.
Overall, PNGC is seeking greater clarity in how the CONE was calculated and greater transparency on how the final $ per kW-yr was modeled and derived in BPM 110.
PNGC generally agrees with this Business Practice and the individual components which encompass the CONE calculations. However, there is a considerable gap in detailing what values were used for each variable, whether the values represent the current market conditions, and how the CONE calculation deploys each variable.
As it stands today, BPM 110 only has a list of the variables and definitions of what is represented with each variable. BPM 110 does not specify which generation technology (or technologies) were used and how that translated into the final CONE value. For example, is the CONE price an average or median of a variety of resources, or does it represent a single price for a selected proxy resource determined by WRAP?
PNGC requests the WRAP provide additional details on these calculations so that we can better assess what the CONE represents and how it may impact participants of the program. At a minimum, conveying what values were used for each input and what proxy resources were modeled in the CONE calculations. For consideration, PNGC views the PJM CONE Study1 as an excellent example of a fully developed CONE pricing study. While PNGC does acknowledge the Brattle CONE study was created for a mature market, we do encourage WRAP to move in this direction over time to a comprehensive, rigorous, and detailed CONE study.
Thank you for the opportunity to provide input into the process.
Submitted Responses
BPM 110 - Cost of New Entry (CONE)
Please supply any comments related to Section 1. Introduction.
Please supply any comments related to Section 2. Background sections
Please supply any comments relatedto Section 3. Calculation of CONE
Please supply any comments related to Section 4. Methodology
Please supply any comments related to Section 5. Annual Review of CONE
Please supply any comments related to Section 6. Changes in CONE
Please supply any comments related to Section 7. Current CONE Value
General Comment
September 29, 2026
Submitted via the WPP Portal and email.
WPP WRAP Program
c/o Maya McNichol
WRAP Policy and Engagement Manager
Re: PNGC Comments on WRAP BPM 110 - Cost of New Entry (CONE)
The Pacific Northwest Generating Cooperative (PNGC) is offering general comments on the WRAP’s proposed Cost of New Entry (CONE) business practice document BPM 110.
Overall, PNGC is seeking greater clarity in how the CONE was calculated and greater transparency on how the final $ per kW-yr was modeled and derived in BPM 110.
PNGC generally agrees with this Business Practice and the individual components which encompass the CONE calculations. However, there is a considerable gap in detailing what values were used for each variable, whether the values represent the current market conditions, and how the CONE calculation deploys each variable.
As it stands today, BPM 110 only has a list of the variables and definitions of what is represented with each variable. BPM 110 does not specify which generation technology (or technologies) were used and how that translated into the final CONE value. For example, is the CONE price an average or median of a variety of resources, or does it represent a single price for a selected proxy resource determined by WRAP?
PNGC requests the WRAP provide additional details on these calculations so that we can better assess what the CONE represents and how it may impact participants of the program. At a minimum, conveying what values were used for each input and what proxy resources were modeled in the CONE calculations. For consideration, PNGC views the PJM CONE Study1 as an excellent example of a fully developed CONE pricing study. While PNGC does acknowledge the Brattle CONE study was created for a mature market, we do encourage WRAP to move in this direction over time to a comprehensive, rigorous, and detailed CONE study.
Thank you for the opportunity to provide input into the process.
Jeff Kugel
Sr. Director Power Operations and Trading
PNGC Power
1. https://www.pjm.com/-/media/DotCom/library/reports-notices/reliability-pricing-model/brattle-cone-report-28-29-reference-resource-and-vrr-curve.pdf