Please supply any comments related to the Join Contract Accreditation Form (JCAF)
No response submitted.
Please supply any comments related to the proposed changes in BPM 106 Qualifying Contracts
No response submitted.
Please supply any comments related to the proposed Embedded Load Acknowledgement and Resource Assurance Agreement
No response submitted.
General Comment
To: WRAP Program Review Committee
From: Committee of State Representatives – Leadership
Date: August 10, 2026
RE: COSR Comment on 2026-NTFP-03: Participant to Participant JCAF and Embedded Entity Resource Agreement Changes
Dear Program Review Committee Members:
Thank you for the opportunity for the Committee of State Representatives (COSR) to review the Non-Task Force Proposal (NTFP) introduced and sponsored by the Western Power Pool (WPP). Recognizing that this proposal is limited to specific implementation provisions that directly impact Western Resource Adequacy Program (WRAP) Participants, the COSR will not be providing formal comments on behalf of the full committee. However, committee members were made aware of this NTFP during their monthly meeting on July 24 with an opportunity to provide feedback or express concerns during the COSR comment period. No such comments were received.
We recognize the benefits of modifying the Business Practice Manual (BPM) to remove the signature requirement for Joint Contract Accreditation Forms (JCAF) between WRAP Participants, recognizing that the Forward Showing software will be used instead to confirm the accuracy of the contracted capacity. We also acknowledge the need for additional BPM language that establishes a mechanism for WRAP Participants to account for their customers’ resources or contracts (in addition to their load), which currently cannot be included in the Participant’s Forward Showing Demonstration. This is particularly applicable when a when the customer’s load is served through a contract with an entity other than the WRAP Participant. Accounting for these arrangements will help improve the accuracy of resource attribution, ensure that contracted capacity is properly reflected in Forward Showing Demonstrations, and avoid unintended gaps between load accounting and resource accounting.
We welcome continued BPM enhancements with the intent of offering additional clarity and guidance for WRAP Participants.
We appreciate the continued efforts to refine and strengthen 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
Submitted Responses
COSR Comment on 2026-NTFP-03
Please supply any comments related to the Join Contract Accreditation Form (JCAF)
Please supply any comments related to the proposed changes in BPM 106 Qualifying Contracts
Please supply any comments related to the proposed Embedded Load Acknowledgement and Resource Assurance Agreement
General Comment
To: WRAP Program Review Committee
From: Committee of State Representatives – Leadership
Date: August 10, 2026
RE: COSR Comment on 2026-NTFP-03: Participant to Participant JCAF and Embedded Entity Resource Agreement Changes
Dear Program Review Committee Members:
Thank you for the opportunity for the Committee of State Representatives (COSR) to review the Non-Task Force Proposal (NTFP) introduced and sponsored by the Western Power Pool (WPP). Recognizing that this proposal is limited to specific implementation provisions that directly impact Western Resource Adequacy Program (WRAP) Participants, the COSR will not be providing formal comments on behalf of the full committee. However, committee members were made aware of this NTFP during their monthly meeting on July 24 with an opportunity to provide feedback or express concerns during the COSR comment period. No such comments were received.
We recognize the benefits of modifying the Business Practice Manual (BPM) to remove the signature requirement for Joint Contract Accreditation Forms (JCAF) between WRAP Participants, recognizing that the Forward Showing software will be used instead to confirm the accuracy of the contracted capacity. We also acknowledge the need for additional BPM language that establishes a mechanism for WRAP Participants to account for their customers’ resources or contracts (in addition to their load), which currently cannot be included in the Participant’s Forward Showing Demonstration. This is particularly applicable when a when the customer’s load is served through a contract with an entity other than the WRAP Participant. Accounting for these arrangements will help improve the accuracy of resource attribution, ensure that contracted capacity is properly reflected in Forward Showing Demonstrations, and avoid unintended gaps between load accounting and resource accounting.
We welcome continued BPM enhancements with the intent of offering additional clarity and guidance for WRAP Participants.
We appreciate the continued efforts to refine and strengthen 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