Comment Submission

Dear Program Review Committee Members:

Thank you for the opportunity for the Committee of State Representatives (COSR) to review the draft proposal on Qualifying Capacity Contributions (QCC) for New Long Duration Storage (LDS).[1] This proposal provides additional guidance on how Western Resource Adequacy Program (WRAP) Participants can establish a QCC for new LDS resources that do not align with existing resource classes. The proposed revisions to Business Practice Manual (BPM) 105 (Qualifying Resources) will enable WRAP Participants to more accurately register new LDS resources that are not adequately represented by existing classifications.

We support the proposed methodology allowing participants to develop and use "synthesized data" for new LDS resources. The temporary use of synthesized data will enable WRAP Participants to establish a QCC using initial outage information based primarily on engineering assumptions and data provided by equipment manufacturers and vendors. As the LDS resource accumulates more operational history, actual performance data will be weighted more heavily than synthesized data and will ultimately become the primary input to the Equivalent Forced Outage Factor (EFOF) calculation.

During the Committee’s review of the proposal, we received a recommendation to include additional language in BPM 105, Section 4.2 that would enable the Program Operator to perform a reasonableness evaluation when synthesized data submitted for a new LDES resource is found to significantly understate or overstate projected resource performance based on the resource's first year of operational data. This modification would enhance consistency within the WRAP framework by aligning treatment of synthesized LDES data with the existing approach applied to years two and three of synthesized VER data under BPM 105, Section 4.3.7.3.

Committee members were provided with an overview of this proposal by the Western Interstate Energy Board staff on July 8, 2026, followed by an opportunity to identify specific concerns or feedback. Aside from the recommendation related to a reasonableness evaluation for synthesized LDS data, no other concerns were raised. We appreciate the continued efforts of WPP staff and WRAP participants to refine and improve various elements of the program.

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

[1] COSR Comment on QCC for New Long Duration Storage - PRC Workplan Task Force 12: https://www.westernpowerpool.org/comments/periods/cosr-comment-on-qcc-for-new-long-duration-storage.