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
Guzman Energy supports the 2026-EP-03 Expedited Proposal establishing a temporary Forward Showing Deficiency Charge Deferral mechanism for the Transition Period. As a load responsible entity, we believe the proposal strikes a fair balance, particularly the Rockies Subregion deferral treatment, which appropriately recognizes that Rockies entities entered the Program more recently and have had comparatively less time and less data available to adapt their procurement, planning, and transmission arrangements to a binding regional resource adequacy construct. Acquiring incremental qualifying capacity in the Rockies Subregion is difficult today, and the additional time afforded by the deferral structure gives Rockies entities a realistic runway to develop and execute a capacity plan rather than facing an immediate charge they cannot procure their way out of. At the same time, the mechanism does not let anyone off the hook: the initial payment, the escalating percentages owed the longer a deficiency persists, the commercially reasonable efforts attestation, and the full 100% obligation upon exit all keep significant dollars committed and preserve the incentive to cure deficiencies promptly. We view this as the right approach to keep entities engaged in WRAP through the Transition Period, and we support its adoption on the understanding that it is temporary and does not establish precedent for any enduring Deficiency Charge policy.
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
Guzman Energy supports the 2026-EP-03 Expedited Proposal establishing a temporary Forward Showing Deficiency Charge Deferral mechanism for the Transition Period. As a load responsible entity, we believe the proposal strikes a fair balance, particularly the Rockies Subregion deferral treatment, which appropriately recognizes that Rockies entities entered the Program more recently and have had comparatively less time and less data available to adapt their procurement, planning, and transmission arrangements to a binding regional resource adequacy construct. Acquiring incremental qualifying capacity in the Rockies Subregion is difficult today, and the additional time afforded by the deferral structure gives Rockies entities a realistic runway to develop and execute a capacity plan rather than facing an immediate charge they cannot procure their way out of. At the same time, the mechanism does not let anyone off the hook: the initial payment, the escalating percentages owed the longer a deficiency persists, the commercially reasonable efforts attestation, and the full 100% obligation upon exit all keep significant dollars committed and preserve the incentive to cure deficiencies promptly. We view this as the right approach to keep entities engaged in WRAP through the Transition Period, and we support its adoption on the understanding that it is temporary and does not establish precedent for any enduring Deficiency Charge policy.