Comment Submission

The Western Power Trading Forum (WPTF) is a California nonprofit, public benefit corporation dedicated to enhancing competition in Western electric markets while maintaining high levels of system reliability. WPTF supports the development of competitive markets throughout the West and fair rules that facilitate transactions among market participants.  WPTF supports WRAP’s vision of a robust RA program which provides regional benefits and promotes reliability across the interconnection. And WPTF supports the continued development and evolution of WRAP, including its enhanced coordination with Markets+ for operationalizing the program.

WPTF comments on the proposed revisions to BPM 106 (Qualifying Contracts) focus on the need to avoid rules that inadvertently provide what may be seen as a simpler/less burdensome process for load-serving entity (LSE)/Load Responsible Entity (LRE) program participants to attest to contracts for capacity in WRAP, as compared to the process for attesting to contracts with independent generators, marketers, and other RA suppliers. More generally, WPTF is concerned with the trend for western RA programs to treat LSE sellers of RA capacity differently than non-LSE sellers of RA capacity for purposes of program participation and contract verification. And this concern is the primary reason for submitting comments on this BPM change, even though we recognize the resolution to this issue would require changes beyond the scope of this BPM.

The underlying cause of western RA program treating non-LSE sellers of RA capacity differently that LSE-sellers, in many instances, can be traced back to the definition of a Participant. The WRAP Tariff defines a Participant as “A Load Responsible Entity that is a signatory to the WRAPA.” This means that any rules that apply to Participants, or make it easier for Participants to attest to contractual exchanges of capacity with one another, are inherently limited to LREs. And this could result in rules that, inadvertently, create higher bars and/or a different set of rules for non-LRE/LSE sellers of RA capacity to have their capacity accredited and counted under WRAP.

Under the proposed revisions to BPM 106, a Resource-Specific Capacity Agreement or System Sale between two WRAP Participants would no longer require a signed Joint Contract Accreditation Form (JCAF). While WPTF supports reducing unnecessary administrative burden in WRAP, which this change could help achieve, we are concerned that the proposal to ease the burden of counting Participant-to-Participant contracts within WRAP could have the unintended consequence of treating certain types of sellers of RA capacity differently for purposes of having their capacity accredited and able to be used in WRAP. Because of the way WRAP Participants are currently defined, under the proposed modifications to BPM 106, the accreditation process by which contracts can be counted in WRAP without a JCAF would be limited to LREs/LSEs. Enabling LRE program participants to accredit contracted capacity without any additional verification/attestation beyond their existing WRAP requirements, but requiring additional verification (via the JCAF) when the seller is not a program Participant, could be seen  as providing a lighter burden for the accreditation of contracts between LSEs in the program.

We understand that the purpose of the BPM modifications is to eliminate what WRAP Participants see as duplicative administrative steps for counting transactions between Participants in the program, given that Participants are already subject to attestation and registration of capacity via the Forward Showing. And WPTF generally supports eliminating duplicative requirements and reducing administrative burdens. But WPTF also supports a program under which verification requirements or contract review standards can apply equally to all types of sellers. Going forward WPTF hopes that there can be a pathway where all sellers of RA capacity could have an option to avoid the JCAF process by instead becoming a program Participant, though we recognize this would require a change in WRAP’s tariff and is beyond the scope of the proposed changes to BPM 106.  As the program continues to evolve, we urge WRAP to consider whether it would be appropriate to expand the definition of program Participant in a way that might help address this concern and could provide the same pathway to accreditation of contracts to non-LSE sellers of RA.