General Comment

To:        Resource Adequacy Participants Committee and Western Power Pool

From:   Committee of State Representatives

Date:    September 13, 2024

RE:        COSR Comments on the Western Resource Adequacy Program Revised Transition Plan

Dear Members of the Resource Adequacy Participants Committee and Western Power Pool,

Thank you for the opportunity to review the Revised Transition Plan (RTP) as published on August 30, 2024. The Committee of State Representatives (COSR) appreciates all the work and effort by the Resource Adequacy Participants Committee (RAPC) and Western Power Pool (WPP) to complete the RTP in a timely manner ahead of the upcoming WPP Board of Directors meeting on September 19, 2024. As part of the Expedited Review Process outlined in Business Practice Manual (BPM) 303, the COSR and other stakeholders have the opportunity to provide comments on the RTP. Our comments are as follows[1]:

The COSR recognizes that the RTP seeks to address the challenges Participants face ahead of their first binding season in the Western Resource Adequacy Program (WRAP), and we generally support the efforts included in this plan that make accommodations for current Participants that are unable to comply with the fully binding program as described in the FERC-approved tariff. With the extended election date for the Summer 2027 binding season, the new Critical Mass provision, and the Excused Transition Deficits (ETDs) and Discounted Deficiency Charges with equal access to holdback capacity, it seems that this proposal gives sufficient flexibility to all Participants that will promote continued support of and engagement in the WRAP during this non-binding phase, the transition period, and into the fully binding program. Additionally, COSR offers the following comments on some of the specific provisions of the RTP.

Binding Season Election

We understand the need and benefits to giving Participants greater time to elect the Summer 2027 (S27) binding season while retaining the current exit provisions, with the intention to encourage more binding participation before Winter 2027-28 (W27-28). The COSR appreciates the RTP’s timeline clarity, and will engage with State-Regulated WRAP Participants (SRWPs) as necessary in advance of the deadlines.

Critical Mass

The COSR appreciates the definition of “Critical Mass” and the inclusion of this provision in the tariff. The COSR recognizes that robust participation is needed to best reap the benefits of the WRAP, and providing parameters for the amount of participation necessary helps to make the concept of Critical Mass more meaningful. The COSR understands the need for the provision to remain non-binding if Critical Mass is not met; we believe this will help Participants and their ratepayers avoid any undue burden from the lack of subregional participation without fully exiting the program, allowing for benefits in the non-binding phase and the opportunity to ease into a future binding season should Critical Mass later be met.

Excused Transition Deficits (ETDs) and Discounts

The COSR appreciates the provision to allow Participants with deficiencies to have equal access to holdback capacity in the program, creating optionality that maximizes sharing and lessens burden. The WRAP has been built on a foundation of collaboration and trust within the Western region, and we hope this provision continues to support that trust-building and to motivate the robust participation necessary to realize a full, fair binding program to support regional resource adequacy by 2029.

We recognize the challenges to creating and releasing this information about the level of regional resource adequacy achieved during the non-binding phase of WRAP and the impact this can have on determining proper levels for the ETDs and Discounted Deficiency Charges during the transition period. Based on interactions with WPP and RAPC, there seems to be a consensus effort to continue to refine these metrics, and the COSR highly encourages WPP and Participants to keep up these discussions to help ensure a more accurate evaluation of the resource adequacy situation in the West and how Participants are showing up in this transition as more information becomes available. Recognizing that entities will likely decide their participation and regulators will evaluate their decisions based on the benefits of the pool, confidently knowing the holdback available to everyone, regardless of their deficiency status, is critical to programmatic success and continued buildout of resources.

The COSR believes the Senior Official Attestation (SOA) that will identify whether a Participant has made commercially reasonable efforts to secure adequate capacity before entering the program is a reasonable measure to improve participation and minimize risk, and we look forward to reviewing the parameters provided by the RAPC and WPP Board of Directors.

Conclusion

The COSR greatly appreciates the efforts by the RAPC and WPP to create this RTP and for consideration of these comments. We recognize that the RTP is a necessary stepping stone for retaining WRAP participation by offering greater flexibility to those that are experiencing deficiencies and other issues along the way to a fully binding program. By moving the RTP forward, the COSR encourages the Participants to continue working with WPP and others to ensure the transition to binding no later than the W27-28 binding season, allowing the region to realize the full benefits of the WRAP as soon as possible. The COSR supports the RTP’s efforts to realize some of those benefits now, and we look forward to future engagement on these issues. 

[1] These comments are not intended to pre-empt, supplant, or otherwise circumvent any state or provincial regulatory processes or determinations. As a standing committee of the WRAP, the COSR exists to provide state and provincial guidance on matters pertaining specifically to the program; Any comments provided by the COSR do not indicate individual member positions on proceedings in their respective states and should not be considered pre-judgment of any kind.