01. Please supply any comments related to the proposed changes in BPM 107 - Section 3.2 Calculating Deficiency Charge
No response submitted.
02. Please supply any comments related to the proposed changes in BPM 107 - Section 7.1 Binding and No-Binding Seasons in Forward Showing Year
No response submitted.
03. Please supply any comments related to the proposed changes in BPM 108 - Section 2.1 FS Deadline Extension Due to Forward Showing Software System Failures
No response submitted.
04. Please supply any comments related to the proposed changes in the WRAP Tariff - Sections 14.6-14.8 (pg. 43)
No response submitted.
05. Please supply any comments related to the proposed changes in the WRAP Tariff - Section 15A.3 (pg. 46)
No response submitted.
06. Please supply any comments related to the proposed changes in the WRAP Tariff - Section 17.4 (pg. 64)
No response submitted.
General Comment
To: WRAP Program Review Committee
From: Committee of State Representatives – Leadership
Date: July 20, 2026
RE: COSR Comment on 2026-NTFP-05: Clarification of FS Deficiency Charges & FS Deadline Extension Due to FS Software Failures
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 June 24 with an opportunity to provide feedback or express concerns during the COSR comment period. No such comments were received.
We acknowledge the benefits of modifying both the Tariff and Business Practice Manual (BPM) 107 with added guidance to address cases where there is both a Non-Binding Season and a Binding Season in a single Forward Showing (FS) Year. WPP’s proposal to zero out the Monthly FS Deficiency Charges for a Non-Binding Summer Season preceding the first Binding Winter Sinding Season will address potential gaming opportunities for participants to artificially inflate the Non-Binding Summer Season’s FS Deficiency to minimize the following Winter Season’s FS Deficiency Charge.
Similarly, we support WPP’s addition of language in the Tariff and BPM 108 to establish a process for addressing instances in which participants are unable to make FS or Cure Period submissions due to a software system outage.
We welcome continued enhancements to the BPM 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 for 2026-NTFP-05
01. Please supply any comments related to the proposed changes in BPM 107 - Section 3.2 Calculating Deficiency Charge
02. Please supply any comments related to the proposed changes in BPM 107 - Section 7.1 Binding and No-Binding Seasons in Forward Showing Year
03. Please supply any comments related to the proposed changes in BPM 108 - Section 2.1 FS Deadline Extension Due to Forward Showing Software System Failures
04. Please supply any comments related to the proposed changes in the WRAP Tariff - Sections 14.6-14.8 (pg. 43)
05. Please supply any comments related to the proposed changes in the WRAP Tariff - Section 15A.3 (pg. 46)
06. Please supply any comments related to the proposed changes in the WRAP Tariff - Section 17.4 (pg. 64)
General Comment
To: WRAP Program Review Committee
From: Committee of State Representatives – Leadership
Date: July 20, 2026
RE: COSR Comment on 2026-NTFP-05: Clarification of FS Deficiency Charges & FS Deadline Extension Due to FS Software Failures
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 June 24 with an opportunity to provide feedback or express concerns during the COSR comment period. No such comments were received.
We acknowledge the benefits of modifying both the Tariff and Business Practice Manual (BPM) 107 with added guidance to address cases where there is both a Non-Binding Season and a Binding Season in a single Forward Showing (FS) Year. WPP’s proposal to zero out the Monthly FS Deficiency Charges for a Non-Binding Summer Season preceding the first Binding Winter Sinding Season will address potential gaming opportunities for participants to artificially inflate the Non-Binding Summer Season’s FS Deficiency to minimize the following Winter Season’s FS Deficiency Charge.
Similarly, we support WPP’s addition of language in the Tariff and BPM 108 to establish a process for addressing instances in which participants are unable to make FS or Cure Period submissions due to a software system outage.
We welcome continued enhancements to the BPM 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