20230510IPC to Staff 1-20_Attachments.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

May 10, 2023

VIA ELECTRONIC FILING

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074

Re: Case No. IPC-E-23-08
In the Matter of Idaho Power Company’s Participation in the Western
Resource Adequacy Program

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Response to the First
Production Request of the Commission Staff to Idaho Power Company in the above-
entitled matter.

If you have any questions about the attached documents, please do not hesitate
to contact me.

Very truly yours,

Lisa D. Nordstrom
LDN:sg
Attachments
RECEIVED
2023 May 10, 4:59PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 1

LISA D. NORDSTROM (ISB No. 5733)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S PARTICIPATION IN THE
WESTERN RESOURCE ADEQUACY
PROGRAM

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CASE NO. IPC-E-23-08

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff (“Commission” or
“Staff”) dated April 20, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 1: Please provide an Excel spreadsheet, with
all formulas intact, showing itemized costs and benefits of the Company participating in
the Western Resource Adequacy Program (“WRAP”), by calendar year through 2030.
Please include cost/benefit analyses from the Company (Utility Cost Test) and ratepayer’s
perspectives (Ratepayer Impact Analysis).
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see the
attachment to this request for a breakdown of costs and benefits associated with WRAP
participation, which shows Company costs beginning in 2022 and benefits associated
with WRAP binding participation beginning in 2027. The Company’s Application and
testimony state that cumulative net benefits for 2027 and 2028 would exceed the
cumulative program costs from 2023-2028 by more than $500,000—these cumulative net
benefits are based on an average of potential high and low Administration Charges. For
the utility cost perspective, the Company provided two views—average estimated costs
and high-end estimated costs.
Additionally, the Company notes that WRAP benefits are avoided costs, not
revenues added to the Company’s income statement. The Company did not perform a
Ratepayer Impact Analysis, as WRAP is not a customer program and, as such, the
avoided costs resulting from WRAP will not have an individualized ratepayer impact.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION NO. 2: Please provide worksheets that show the
Company’s assumptions and calculations of the WRAP Administration Charges.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: The structure and
authorized formula for determining the WRAP Administration Charge is included as
Schedule 1 to the WRAP Tariff, a searchable version of which is provided in response to
Staff’s Production Request No. 9.
The Company estimates that the annual cost of participation—or the annual sum
of WRAP Administration Charges—will be between $510,133 and $744,555. The WRAP
Administration Charge includes both a fixed administration cost component and a variable
operating cost component. The variable component is allocated based on each
participant’s percent of total monthly P50 load value in megawatts (“MW”). Given these
requirements, the estimated cost range was derived as follows:
Low estimate: $59,000 + ($199/MW * 2,267 MW) = $510,133 annually
High estimate: $59,000 + ($199/MW * 3,445 MW) = $744,555 annually
where $59,000 and $199/MW are the maximum charge rates provided in the WRAP
Tariff.1 The load value included in the Company’s low estimate is the median Monthly
P50 load value from the two most recent Forward-Showing submittals (i.e., one Forward
Showing for summer 2023 and one Forward Showing for winter 2023/2024).2
As of February 2023, Western Power Pool determined this value to be 2,267 MW.
Meanwhile, the load value included in the Company’s high estimate was based on the
maximum average of Idaho Power’s monthly peak summer load.

1 WRAP Tariff, Schedule 1, Section 3.
2 Id., Section 2.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 4
A workpaper showing the calculations described above is included as an
attachment to this request.
The response to this Request is sponsored by Nicole Blackwell, Lead Operations
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST FOR PRODUCTION NO. 3: Company witness Williams states: “WRAP
participants must pay non-compliance charges if they fail to meet the requirements of the
forward-showing and operations programs. These non-compliance charges include
Deficiency Charges and Delivery Failure Charges, and they are designed to result in
compliance from all participants.” Williams Direct at 22. Please explain the likely
magnitude of the charges and the factors that would determine the magnitude of each
type of charge. Please explain whether the Company will seek recovery for these charges
and the conditions when they would or would not seek recovery.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The Company will not
participate in WRAP in such a way that would incur either Deficiency Charges or Delivery
Failure Charges. As described below, the magnitude of these charges is designed to
incentivize compliance. That said, in the extremely unlikely event that the Company would
incur such charges, the Company would first seek to understand the circumstances that
led to such charges before determining whether the Company should absorb those costs
or whether it would be appropriate to seek recovery from customers.
The Deficiency Charge is structured to reflect the relative magnitude of a
participant’s seasonal deficiency and the estimated cost to remedy that deficiency with a
new peaking natural gas-fired generation facility (the estimated cost of a new facility is
annually reviewed by WPP).3 A deficient participant will be charged based on the largest
monthly deficiency identified in a specific season’s Forward Showing and will incur
additional charges for each additional deficient month in that season.4 Further, if a

3 Section 17 of WRAP Tariff.
4 Section 17.2 of WRAP Tariff.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 6
participant is deficient in a summer operating season and demonstrates greater
deficiency in the subsequent winter operating season, additional charges will be
incurred.5 Therefore, the Deficiency Charge reflects the magnitude and duration of a
participant’s capacity deficiency and WPP’s estimated cost of a new peaking natural gas-
fired generation facility.
The Delivery Failure charge is structured to reflect the relative magnitude of a failed
energy delivery and the estimated value of that un-delivered energy relative to the Day-
Ahead or Real-Time Price Index.6 If a participant fails to provide energy and that deficit is
not entirely covered by other program participants, the Delivery Failure Charge will be
several times greater than if the deficit were entirely covered by other participants.7
Additionally, for each additional energy delivery failure within a rolling five-year window,
a participant’s Delivery Failure Charge doubles in magnitude (up until a capped amount).
Therefore, the Delivery Failure Charge significantly increases with the frequency of
failures, amount covered by other participants, and the market price index used.
It is worth noting that Deficiency Charges and Delivery Failure Charges cannot be
applied until Idaho Power is a binding participant. If, during the non-binding period, the
Company identifies it could operate in such a way as to incur either type of charge, the
Company will reevaluate its participation in WRAP.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Leader, Idaho Power Company.

5 Id.
6 Section 20.7 of WRAP Tariff.
7 Section 20.7.4 of WRAP Tariff.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 7
REQUEST FOR PRODUCTION NO. 4: If the Company opts for fully binding
WRAP participation, and subsequently changes its mind, please explain the requirements
for the Company to exit WRAP, the likely timeline, and the likely costs.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Idaho Power and all other
WRAP participants have two options if they choose to withdraw from WRAP, as detailed
in the WRAP Tariff:
1. Normal Withdrawal8: A participant may withdraw from WRAP by providing
written notice to Western Power Pool (“WPP”) no less than 24 months prior to
commencement of the next binding Forward Showing season. Once notice is
properly given, the withdrawing participant remains in a “Withdrawal Period”
until the Withdrawal Date. There is no exit fee for Normal Withdrawal. However,
the withdrawing participant is still subject to all program requirements and
financial obligations imposed by the WRAP Tariff during the Withdrawal Period.
2. Expedited Withdrawal9: If the impact of a participant’s withdrawal on the WRAP
Operations Program can be calculated with a high degree of confidence and
mitigated by the payment of an exit fee, a participant may be permitted to
withdraw from WRAP with less than the required 24-months’ notice. The exit
fee would include, but not be limited to, the participant’s unpaid WRAP fees or
charges, administrative costs incurred up to the next Forward Showing period,
costs incurred by WPP and/or the Program Operator directly resulting from the

8 Section 9.1 of WRAP Tariff.
9 Section 9.2 of WRAP Tariff.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 8
participant’s withdrawal, and any costs necessary to hold other participants
harmless from the voluntary expedited withdrawal.
The response to this Request is sponsored by Nicole Blackwell, Lead Operations
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 9
REQUEST FOR PRODUCTION NO. 5: Please provide workpapers detailing
analysis and assumptions for any other costs associated with participation in the WRAP
(i.e., operations costs, incremental resource or transmission costs, penalties, exit costs,
etc.). Please specify if costs are specific to the binding period.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Deficiency Charges and
Delivery Failure Charges are discussed in Idaho Power’s response to Staff’s Request for
Production No. 3. In the attachment to this response, the Company provides a
hypothetical example of a Deficiency Charge the Company could potentially incur. Please
note this example is for illustrative purposes only and is not intended to reflect costs the
Company is anticipating it will incur. Idaho Power fully expects and plans to resolve any
future Forward-Showing deficiencies through purchases made in the cure period, rather
than through payment of a Deficiency Charge.
Exit fees are discussed in the Company’s response to Staff’s Request for
Production No. 4. The Company has not contemplated exiting WRAP at this stage and,
as such, has no supporting analysis of exit fees.
Other potential costs or payments, beyond what is discussed in the Company’s
Responses to Request for Production Nos. 2-4, include the settlements for Holdback
Requirements and Energy Deployments in the Operations Program and are only
applicable to binding operations. Idaho Power does not have workpapers regarding these
costs, as they are dependent on the holdbacks and deployments that occur within a
specific operating season, which has yet to commence.
The response to this Request is sponsored by Nicole Blackwell, Lead Operations
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 10
REQUEST FOR PRODUCTION NO. 6: Company witness Williams states: “The
Reliability and Capacity Assessment Tool analysis found that WRAP, by providing
capacity resources to the Company on that single worst day, resulted in the Company
needing 14 megawatts (‘MW’) less of perfect generation to meet an annual Loss of Load
Expectation (‘LOLE’) of 0.1 event-days per year.” Williams Direct at 15. Please provide
the data and worksheets showing this determination.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Idaho Power utilized
MathWorks computing environment and programming language MATLAB® to develop
the current Reliability & Capacity Assessment Tool (“RCAT”), which is comprised of
scripts and functions that allow for detailed modeling and representation of the Company's
system. Please see the attached Excel spreadsheet, WRAP Analysis, for the requested
RCAT modeling details and results.
The response to this Request is sponsored by Andrés Valdepeña Delgado, System
Planning Engineer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 11
REQUEST FOR PRODUCTION NO. 7: Company witness Williams states: “The
cost savings presented above assumes the Company will rely on the WRAP operations
program’s resource sharing only once per year… Leveraging the program more
frequently would potentially result in additional avoided cost savings.” Williams Direct at
17. Please answer the following questions:
a. Please explain how leveraging the program more frequently might result in
additional avoided cost savings;
b. Please explain and quantify any penalties or consequences whenever the
Company uses the WRAP resource sharing, whether once a year, or more
frequently;
c. Please explain if there are limits on how frequently the Company can use the
WRAP resource sharing each year; and
d. Please explain if any expenses would be reduced if the Company does not use
the WRAP resource sharing.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7:
a. Idaho Power applied the same methodology as described in the Response to
Request for Production No. 6 to determine whether more frequent use of
WRAP would produce additional avoided cost savings. The Company’s
analysis using the Reliability & Capacity Assessment Tool (“RCAT”)
determined that utilizing WRAP twice per year would result in the avoidance of
24 MW of perfect generation and annual avoided cost savings of $3.7 million.
The Company did not present the twice-per-year view in its Application in this
case because WRAP is designed and intended to be leveraged as a last-resort

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 12
program. As such, the Company does not yet know how often it would use the
program and, therefore, considers the one-time-per-year view the best initial
estimate of use.
b. There are currently no penalties or consequences for utilizing the WRAP
Operations Program for capacity. However, there are financial settlements that
would occur for Holdback Requirements and Energy Deployments, as
described in Section 21 of the WRAP Tariff.
c. There are currently no limits on how frequently the Company can utilize the
WRAP Operations Program for capacity.
d. WRAP participation costs are not impacted by utilizing the Operations Program
for capacity, or lack thereof. Therefore, participation costs would not be
reduced if the Company did not utilize the WRAP Operations Program for
capacity.
The response to this Request is sponsored by Andrés Valdepeña Delgado, System
Planning Engineer, and Nicole Blackwell, Lead Operations Analyst, Idaho Power
Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 13
REQUEST FOR PRODUCTION NO. 8: Please explain the benefits the Company
expects by committing to an earlier binding date.
a. Please include a current list of other utilities and their binding/non-binding status;
and
b. Please describe metrics and considerations the Company will use to evaluate the
feasibility of committing to an earlier binding date.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Idaho Power tentatively
plans to begin binding WRAP participation in the summer of 2027 but will continue to
evaluate whether committing to an earlier binding date is beneficial. The greater the
number of binding WRAP participants, the greater the diversity of loads and resources
and more broadly deficiencies and surpluses can be reconciled, which provides an
insurance benefit of sorts—the greater the size of the pool, the less risk for both the
individual participant and the collective pool.
a. WRAP participants are continuing to discuss the timing of their transition to binding
participation, and final dates are to be determined. Therefore, Idaho Power does
not have information on the dates that other participants plan or expect to begin
binding participation.
The list of current WRAP participants is as follows:10
 Arizona Public Service
 Avista
 Bonneville Power Administration
 Calpine

10 Western Power Pool, WRAP Area Map (Last modified April 5, 2023).

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 14
 Chelan County PUD
 Clatskanie PUD
 Eugene Water & Electric Board
 Grant PUD
 Idaho Power
 Northwestern Energy
 NV Energy
 PacifiCorp
 Portland General Electric
 Powerex
 Public Service Company of New Mexico
 Puget Sound Energy
 Salt River Project
 Seattle City Light
 Shell Energy
 Snohomish PUD
 Tacoma Power
 The Energy Authority
b. Idaho Power would consider an earlier binding date if a critical mass of other
participants collectively began their binding participation at an earlier binding date.
In any case, Idaho Power plans to fully evaluate all information available at the
time it is considering beginning binding participation, including but not limited to
the outcome of this docket, and its experience in the non-binding phases of WRAP.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 15
The response to this Request is sponsored by Nicole Blackwell, Lead Operations
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 16
REQUEST FOR PRODUCTION NO. 9: Please provide a text-searchable version
of Exhibit No. 1.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: Please see the attached
document, Text-Searchable Exhibit No. 1.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 17
REQUEST FOR PRODUCTION NO. 10: The success of WRAP rests on the
likelihood that some participants will have surplus capacity when other participants have
need. Please provide any information the Company used to assess the likelihood of
resources being available during the Company’s critical capacity hours. Please provide
the peak season (winter or summer) for all other utilities participating in the WRAP.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: To clarify, the success
of WRAP depends on the coordinated planning of resources in the region according to
requirements set by the modeling and analysis completed by the Program Operator,
which will ensure region-wide reliability and allow the program and participants to
leverage the diversity of loads and resources and further enhance region-wide reliability.
Idaho Power has not assessed the likelihood of resources being available during
the Company’s capacity critical hours. In the Forward Showing planning context, Idaho
Power is not planning to use the sharing in the WRAP Operations Program during any
hours, although it (and other participants) will have the opportunity to do so if there are
changes in actual load or resource availability as compared to the Forward Showing plan.
From a planning perspective, participants must equally and individually plan to
meet their own capacity requirements in the Forward Showing, or else be subject to
Deficiency Charges. The Forward-Showing capacity requirement is based on Planning
Reserve Margin calculations and the qualifying capacity contribution of resources to
ensure that, collectively, participants are able to maintain reliability during extreme peak
events. In the Forward Showing, Idaho Power plans to meet its capacity requirements.
In the Operations Program, participants that are deficient due to changes in load
or resource balance as compared to the Forward Showing may be able to call on energy

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 18
holdbacks from other participants who are surplus. Thus, if a participant is deficient in the
Operations Program due to changes from its Forward Showing load and resource
assumptions, it will be able to utilize the sharing in the Operations Program. The
Company’s response to Staff’s Production Request No. 3 describes the penalties
associated with capacity deficiencies identified in the Forward Showing as well as
penalties associated with failed energy delivery in the Operations Program.
Idaho Power does not have information related to the peak season for other WRAP
participants. Generally, Idaho Power understands that utilities in the Pacific Northwest
(“PNW”) tend to be winter-peaking, and utilities in the Desert Southwest (“DSW”) tend to
be summer-peaking. Figures 1 and 2 below illustrate the general PNW and DSW
seasonal peaks using historical FERC 714 data.

Figure 1: Historical PNW Seasonal Peaks

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 19

Figure 2: Historical DSW Seasonal Peaks

The response to this Request is sponsored by Nicole Blackwell, Lead Operations
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 20
REQUEST FOR PRODUCTION NO. 11: Some WRAP participants are subject to
clean energy mandates. Please answer the following:
a. Please explain how WRAP will incorporate those mandates into its forward
showing and operations programs; and
b. Please explain if the Company will be either indirectly or directly required to provide
clean power into the WRAP programs.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11:
a. WRAP will not incorporate participants’ clean energy mandates into Forward-
Showing or Operations Program obligations. WRAP participants retain full control
over their systems, planning, and resource decisions. To the extent that a
participant is subject to a state clean energy mandate, it would be addressed as
part of the participant’s autonomous resource planning function and resource
procurement, or bilateral energy purchases made wholly outside of WRAP. WRAP
itself has no clean energy component and WRAP requirements do not specify the
types of resources or the amount of generation that must come from those
resources. Rather, any load or generation resource that meets the qualifications
and accreditation requirements, including registration with WRAP, as established
in the WRAP Tariff, is considered a qualifying resource. Therefore, all resource
types, such as thermal resources, variable energy resources, and energy storage
may be qualifying resources.
b. Idaho Power will not be required, neither directly nor indirectly, to provide clean
power into WRAP.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 21
The response to this Request is sponsored by Nicole Blackwell, Lead Operations
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 22
REQUEST FOR PRODUCTION NO. 12: Please explain how the Company’s
differing calculation for Planning Reserve Margin (“PRM”) may impact the resource and
transmission capacity requirements determined by the WRAP.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: Idaho Power’s planning
reserve margin (“PRM”) is calculated for system-specific, long-term Integrated Resource
Planning (“IRP”) purposes and is based on the Company’s forecasted loads and
resources. IRP modeling employs a number of IRP-specific assumptions that do not carry
over into WRAP’s regional (and shorter-term) planning. Idaho Power’s specific PRM and
IRP determine whether, on a long-term basis, the Company is forecast to have supply
surpluses or deficiencies, and, therefore, determines the amount of capacity that Idaho
Power needs to procure on a long-term basis.
In contrast, WRAP’s calculation of generation or transmission capacity
requirements is based on WRAP-specific assumptions, described in the WRAP Tariff and
associated design documents. WRAP takes a regional view of loads and resources, as
opposed to utility-specific view, and evaluates over a short-term time horizon.
Idaho Power’s Forward-Showing submittal and resource demonstration will
include resources or transmission that Idaho Power has developed or procured. As Idaho
Power identifies its long-term capacity needs in its IRP and procures sufficient generation
and transmission capacity to meet those needs, the Company fully expects it will have
the resources and capacity needed to successfully comply with WRAP’s Forward-
Showing requirements. Further, as resources or transmission are added to the regional
footprint, that capacity will be included in WRAP’s calculation of loads and resources and
WRAP’s PRM. As such, the Company’s PRM has an indirect impact on—but no direct

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 23
connection to—the resource and transmission capacity requirements determined by
WRAP.
The response to this Request is sponsored by Camille Christen, Resource
Acquisition, Planning and Coordination Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 24
REQUEST FOR PRODUCTION NO. 13: Please describe how the reduction in
planning reserve margin PRM expected from participating in the WRAP will affect the
Company’s capacity deficiency dates.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: Idaho Power’s PRM is
derived based on a variety of factors, including resource availability, capacity contribution
of those resources, and calculated resource need. As shown in the Company’s response
to Staff’s Production Request No. 6, WRAP’s benefit is calculated based on the ability to
reduce the Company’s need for perfect generation by using WRAP one time per year. As
a result, WRAP reduces the amount of procured resources needed by the Company and
indirectly decreases the Company’s PRM. Importantly, the Company’s PRM is a derived
variable that is unlikely to go down in a linear fashion. In fact, it may go up or down from
IRP to IRP. What will remain consistent is that the ability to leverage WRAP allows for a
lower PRM than the Company would have had in the absence of WRAP.
The Company did not model the impact of WRAP until 2027 and currently expects
the capacity deficit in that year will be greater than the 14 MW that WRAP is expected to
provide by using the program one time per year. Therefore, WRAP participation is not
expected to affect Idaho Power’s capacity deficiency dates.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
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REQUEST FOR PRODUCTION NO. 14: Please clarify how the forward showing
program will set prices and engage members to reserve generation capacity and
transmission capacity.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: The Forward Showing
program does not set prices or engage members to reserve generation capacity and
transmission capacity. The purpose of the Forward Showing program is for individual
participants to prove they can meet WRAP’s load and Planning Reserve Margin-based
capacity requirements and, if unable, either cure deficiencies during the specified
timeframe or pay the Deficiency Charge for non-compliance. Energy or generation
capacity purchases, as well as transmission capacity purchases, may be used to cure
deficiencies, but the terms, conditions, and pricing would be bilaterally negotiated.
Therefore, the Forward Showing program itself does not obligate participants to make
particular purchases and it does not set prices. Rather, pricing for any purchases to cure
Forward Showing deficiencies would be established through bilateral negotiations or the
applicable entity’s Open Access Transmission Tariff pricing.
It is during the Operations Program of WRAP (which follows each season’s
Forward Showing) that participants may be assigned holdback requirements or be eligible
to receive energy deployments and, therefore, be charged (or paid) in accordance with
the price structures approved in the WRAP Tariff.
The response to this Request is sponsored by Nicole Blackwell, Lead Operations
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 26
REQUEST FOR PRODUCTION NO. 15: Please provide the settlement quantities
and prices calculated by Western Power Pool (“WPP”) for the Summer 2023 season
holdback requirements and energy deployments described in Blackwell Direct at 16.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: Holdback requirements
and energy deployments—as well as any settlement quantities and prices—will be
determined in near real-time during each season’s Operating Program. Because WRAP
has not yet had an Operations Program, Idaho Power does not have the requested
information at this time.
The first non-binding Operations Program is scheduled for the Winter 2023/2024
season. Please refer to Section 21 of the WRAP Tariff, provided with the response to
Staff’s Production Request No. 9, for more information on the nature of Operations
Program settlements.
The response to this Request is sponsored by Nicole Blackwell, Lead Operations
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 27
REQUEST FOR PRODUCTION NO. 16: For resources to be used for the WRAP
Summer 2023 season, please provide the expected WRAP Tariff holdback compensation
that is described in Blackwell Direct at 19.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: Please see the
response to Staff’s Production Request No. 15. In Summer 2023, WRAP is performing
testing of the Operations Program information sharing functionality, but the first non-
binding Operations Program is planned for Winter 2023/2024.
The response to this Request is sponsored by Nicole Blackwell, Lead Operations
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
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REQUEST FOR PRODUCTION NO. 17: Please describe how often the Company
expects to hold back or deploy resources into the WRAP.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: Idaho Power is not able
to predict how often it will be subject to holdback requirements or energy deployments in
the Operations Program. Holdback requirements and energy deployments will be highly
dependent on near-term operating conditions for all WRAP participants, which can be
impacted by various factors such as changes in demand, expected generation from
variable energy resources, and unplanned outages. However, Idaho Power will not be
called upon for holdback or energy deployment if it does not have excess capacity to
contribute to the Operations Program.
The response to this Request is sponsored by Nicole Blackwell, Lead Operations
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 29
REQUEST FOR PRODUCTION NO. 18: Please explain if the Company plans to
file any notices or cases with the IPUC prior to committing to a binding period with the
WRAP.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18: Yes, Idaho Power will
alert the Commission in this docket or via alternate regulatory notice prior to committing
to a WRAP binding period.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 30
REQUEST FOR PRODUCTION NO. 19: Please explain if the Company expects
to use its demand response programs as a resource available for use in the WRAP
forward showing program.
a. If yes, please provide workpapers detailing the cost-effectiveness analysis
of the Company’s demand response programs using the avoided resource
investment benefit of participating in the WRAP.
b. If not, please explain why not.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: No, the Company does
not expect to use demand response programs as a capacity resource available for use in
the WRAP Forward Showing program. Demand response programs can be accounted
for in a Forward-Showing submittal in one of two ways: either as a load modifier or as a
capacity resource. Demand response programs that are registered as a load modifier are
listed as a separate line item in a participant’s Forward-Showing submittal and will be
subtracted directly from the participant’s P50 load responsibility. Meanwhile, demand
response programs that are registered as a capacity resource are considered resources
that serve the participant’s load and can be separately identified from load or metered.
Because Idaho Power’s demand response programs are used during the summer
season to reduce peak load, the Company registered its demand response programs as
load modifiers and has included them as such in its non-binding Forward Showing
submittals thus far. Therefore, the Company’s demand response programs are not
treated as capacity resources in the Forward Showing.
The response to this Request is sponsored by Nicole Blackwell, Lead Operations
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 31
REQUEST FOR PRODUCTION NO. 20: Company witness Blackwell notes that
WRAP methods for assessing resource adequacy are significantly different than the
Company’s methods. Blackwell Direct at 5. This will create a new layer of planning
factors that the Company might consider. For example, each resource will have a
different capacity contribution for WRAP in the summer, for WRAP in the winter, and for
the Company’s internal Load and Resource Balance. Please describe how the Company
plans to manage this additional complexity. Please explain how the Company will
prioritize between those differences when making planning resource decisions.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20: Idaho Power
recognizes that complexities exist between short-term planning in WRAP and long-term
planning associated with the Company’s Integrated Resource Plan (“IRP”). The Company
introduced these differences in its Application and associated testimony of witnesses to
show an awareness of and comfort with the two distinct planning methodologies.
Idaho Power’s Planning team conducts long-term planning with the IRP, while the
Company’s Load Serving Operations manages WRAP, including development of
Forward-Showing submittals and participation during the Operations Program. While
Idaho Power’s teams always confer and collaborate on cross-functional issues, the IRP
and WRAP are discrete planning exercises with entirely different functions and purposes
and, thereby, are supported by different and appropriate parts of the Company.
To be clear, the Company does not intend to change the way it models reliability
because of or to align with WRAP. Rather, the Company will continue using its current
methodologies to ensure its system can maintain Company-chosen reliability standards.
Meanwhile, the Company will continue to work with WRAP and maintain awareness of

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 32
WRAP’s methodologies, how they differ from Idaho Power’s methodologies, and ensure
that Idaho Power is meeting its Forward-Showing requirements based on WRAP’s
assessment of the regional landscape.
The response to this Request is sponsored by Nicole Blackwell, Lead Operations
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 33

DATED at Boise, Idaho, this 10th day of May 2023.

________________________________
LISA D. NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 34
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 10th day of May 2023, I served a true and correct
copy of Idaho Power Company’s Response to the First Production Request of the
Commission Staff to Idaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:

Commission Staff
Michael Duval
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Stacy Gust, Regulatory Administrative
Assistant

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-08

IDAHO POWER COMPANY

REQUEST NO. 1

ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-08

IDAHO POWER COMPANY

REQUEST NO. 2

ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-08

IDAHO POWER COMPANY

REQUEST NO. 5

ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-08

IDAHO POWER COMPANY

REQUEST NO. 6

ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-08

IDAHO POWER COMPANY

REQUEST NO. 9

ATTACHMENT NO. 1

WESTERN RESOURCE ADEQUACY PROGRAM
TARIFF
OF
NORTHWEST POWER POOL
D/B/A
WESTERN POWER POOL

TABLE OF CONTENTS

PART I GENERAL PROVISIONS 1. Definitions 2. Role of Western Power Pool 3. Role of the Board of Directors and Limitations on Board Authority
4. Organizational Groups for the WRAP 5. Independent Evaluator 6. WPP Invoicing and Settlement 7. Credit Requirements and Settlement for Holdback and Delivered Energy 8. Force Majeure, Limitation of Liability, and Indemnification
9. Dispute Resolution Procedures 10. Treatment of Confidential and Commercially Sensitive Information of Participants 11. Timing 12. Application and Registration
PART II FORWARD SHOWING PROGRAM 13. Overview 14. Forward Showing Program Process and Timeline 15. Transition Period 16. Components of the Forward Showing
17. Forward Showing Deficiency Charge PART III OPERATIONS PROGRAM 18. Operations Program Overview 19. Operations Program Timeline and Supporting Information
20. Components of the Operations Program 21. Operations Program Settlements SCHEDULE 1 WESTERN RESOURCE ADEQUACY PROGRAM ADMINISTATIVE COST RECOVERY
CHARGE ATTACHMENT A Western Resource Adequacy Program Agreement

PART I GENERAL PROVISIONS

1. Definitions
Unless the context otherwise specifies or requires, capitalized terms used in this Tariff shall have
the respective meanings assigned herein for all purposes of this Tariff (such definitions to be equally applicable to both the singular and the plural forms of the terms defined). Unless otherwise specified, all references herein to Parts, Sections, Schedules, or Attachments, are to Parts, Sections, Schedules, or Attachments of this Tariff.
Applicable Price Index: A published index of wholesale electric prices, or Locational Marginal
Prices duly calculated and posted by a FERC-regulated market operator, in either case as designated under Part III of this Tariff for use in connection with an identified Subregion.
Administration Charge or WRAP Administration Charge: The charge established under Schedule 1 of this Tariff for recovery of the costs of the WRAP.
Advance Assessment: Analyses and calculations of Participant load, resource, and other
information performed in advance of each Binding Season as set forth in Part II of this Tariff. Available Transfer Capability (“ATC”): Transfer capability remaining in the physical transmission network for further commercial activity over and above already committed uses.
Balancing Authority: The responsible entity that integrates resource plans ahead of time, maintains demand and resource balance within a Balancing Authority Area, and supports interconnection frequency in real time. Balancing Authority Area: The collection of generation, transmission, and loads within the
metered boundaries of the Balancing Authority. The Balancing Authority maintains load-resource balance within this area. Base Charge: A component of the WRAP Administration Charge as established under Schedule
1 of this Tariff.
Base Costs: Base Costs shall have the meaning provided in Schedule 1 of this Tariff.
Base Services Cost Centers: The cost centers comprising the Base Charge as defined in Schedule 1 of this Tariff.
Base Services Percentage: Base Services Percentage shall have the meaning provided in
Schedule 1 of this Tariff.
Binding Season: The Summer Season or the Winter Season.
Board of Directors or Board: The Board of Directors of the Northwest Power Pool d/b/a Western Power Pool.
Business Day: Any Day that is a Monday through Friday, excluding any holiday established by
United States federal authorities.

Business Practice Manuals: The manuals compiling further details, guidance, and information
that are appropriate or beneficial to the implementation of the rules, requirements, and procedures
established by this Tariff. Business Practice Manuals do not include such internal rules or procedures as the Western Power Pool may adopt for its operation and administration, including but not limited to any corporate by-laws of the Western Power Pool, or for any services or functions provided by the Western Power Pool other than those established by this Tariff.
CAISO: The California Independent System Operator Corporation, a California nonprofit public
benefit corporation.
Capacity Benefit Margin: An amount of transmission transfer capability permitted under open access transmission rules to be reserved by load serving entities to ensure access to generation from interconnected systems to meet generation reliability requirements.
Capacity Critical Hours (“CCH”): Those hours during which the net regional capacity need
for the WRAP Region is expected to be above the 95th percentile, based on historic and synthesized data for the WRAP Region’s gross load, variable energy resource performance, and interchange.
Capacity Deficiency: A shortfall in a Participant’s Portfolio QCC relative to that Participant’s
FS Capacity Requirement, as further defined in Part II of this Tariff.
Cash Working Capital Fund: Cash Working Capital Fund shall have the meaning provided in Schedule 1 of this Tariff.
Cash Working Capital Support Charge: A charge assessed to Participants under Schedule 1 of this Tariff to fund the Cash Working Capital Fund.
Cash Working Capital Support Charge Rate: Cash Working Capital Support Charge Rate shall
have the meaning provided in Schedule 1 of this Tariff.
Cost of New Entry (“CONE”): The estimated cost of new entry of a new peaking natural gas-fired generation facility, as determined under, and used in, Part II of this Tariff.
CONE Factor: A factor employed in the calculation of Deficiency Charges under Part II of this
Tariff, to reflect whether, and the extent to which, the WRAP Region as a whole is expected to
have a capacity deficiency during the period for which the Deficiency Charge is bring calculated.
Committee of State Representatives (“COSR”): Committee of State Representatives, as established in Part I of this Tariff.
Contingency Reserve: As more fully described in the NERC WECC reliability standards, a
quantity of reserves, consisting of generation, load, interchange, or other resources, that are
deployable within ten minutes, equal to the greater of (i) the MW quantity of the loss of the most severe contingency and (ii) the megawatt quantity equal to the sum of 3% of hourly integrated load plus 3% of hourly integrated generation.

Cumulative Delivery Failure Period: Any period of five consecutive years, ending with and
including the most recent Energy Delivery Failure as of the time of determination of a possible
Delivery Failure Charge.
Day: A calendar day.
Day-Ahead Price: A price for wholesale electric transactions designated as a day-ahead price in
an Applicable Price Index.
Default Allocation Assessment: A charge assessed on non-defaulting Participants to recover the
costs associated with a default by a Participant, as set forth in Part I of this Tariff.
Deficiency Charge: A charge assessed for a Capacity Deficiency or Transmission Deficiency, as set forth in Part II of this Tariff.
Delivery Failure Charge: A charge assessed for a Participant’s failure to deliver a required
Energy Deployment, as set forth in Part III of this Tariff.
Delivery Failure Charge Rate: A rate employed in the determination of a Delivery Failure Charge as more fully set forth in Part III of this Tariff.
Delivery Failure Factor: A factor used in the determination of a Delivery Failure Charge to recognize the relative severity or impact of an Energy Delivery Failure, as set forth in Part III of
this Tariff.
Demand Response: A resource with a demonstrated capability to provide a reduction in demand or otherwise control load in accordance with the requirements established under Part II of this Tariff.
Demonstrated FS Transmission: A Participant’s demonstration in its Forward Showing
Submittal that it has secured firm transmission service rights of the type and quantity sufficient to provide reasonable assurance, as of the time of the Forward Showing Submittal, of delivery of capacity from the Qualifying Resources and the resources associated with the power purchase agreements in the Participant’s Portfolio QCC.
Dual Benefit Cost Centers: Dual Benefit Cost Centers shall have the meaning provided in
Schedule 1 of this Tariff.
Effective Load Carrying Capability (“ELCC”): A methodology employed to determine the Qualified Capacity Contribution of certain types of Qualifying Resources, as more fully set forth in Part II of this Tariff.
Energy Declined Settlement Price: A pricing component used as part of the calculation of
settlements for Holdback Requirements and Energy Deployments under Part III of this Tariff. Energy Delivery Failure: A failure by a Participant to provide an Energy Deployment assigned to such Participant under Part III of this Tariff.

Energy Deployment: A delivery of energy that a Participant is required to provide during an
Operating Day, as set forth in Part III of this Tariff.
Energy Storage Resource: A resource, not including a Storage Hydro Qualifying Resource, designed to capture energy produced at one time for use at a later time.
Excused Transition Deficit: A Participant’s inability during the Transition Period to demonstrate full satisfaction of the Participant’s FS Capacity Requirement, which, under certain conditions and
limitations prescribed by Part II of this Tariff, permits a reduction in the otherwise applicable
Deficiency Charge.
Federal Power Marketing Administration: A United States federal agency that operates electric systems and sells the output of federally owned and operated hydroelectric dams located in the United States.
FERC: The Federal Energy Regulatory Commission.
Forced Outage Factor: The factor resulting from dividing the number of hours a generating unit or set of generating units is not synchronized to the grid system, not in reserve shutdown state and considered to be out of service for unplanned outages—or a startup failure, by the number of total hours in the period multiplied by 100% or a Program Administrator calculated equivalent forced
outage factor that reflects the likelihood and extent to which a resource will be unavailable from
time to time due to factors outside management control.
Forward Showing Program: The program and requirements as set forth in Part II of this Tariff.
Forward Showing Submittal (“FS Submittal”): The submissions a Participant is required to submit in advance of each Binding Season to demonstrate its satisfaction of the FS Capacity
Requirement and FS Transmission Requirement, as set forth in Part II of this Tariff.
Forward Showing Year: A period consisting of a Summer Season and the immediately succeeding Winter Season.
FS Capacity Requirement: The minimum quantity of capacity a Participant is required to demonstrate for a Binding Season, as set forth in Part II of this Tariff.
FS Deadline: The deadline for Participants’ submissions of their FS Submittals for a Binding
Season, as established under Part II of this Tariff.
FS Planning Reserve Margin (“FSPRM”): An increment of resource adequacy supply needed to meet conditions of high demand in excess of the applicable peak load forecast and other conditions such as higher resource outages, or lower availability of resources, expressed as a
percentage of the applicable peak load forecast, as determined in accordance with Part II of this
Tariff.
FS Transmission Requirement: The minimum quantity of transmission service rights a Participant is required to demonstrate for a Binding Season, as set forth in Part II of this Tariff.

High-Priced Day: The most recent day in the CAISO in which prices in the day-ahead market
were at least $200/MWh.
Holdback Requirement: A MW quantity, as determined on a Preschedule Day, that a Participant is required to be capable of converting into an Energy Deployment on a given hour of the succeeding Operating Day, as more fully set forth in Part III of this Tariff.
ICE Index: A wholesale electric price index prepared and published by the Intercontinental
Exchange.
Incremental Cash Working Capital Support Charge: Incremental Cash Working Capital Support Charge shall have the meaning provided in Schedule 1 of this Tariff.
Independent Evaluator: An independent entity engaged to provide an independent assessment of the performance of the WRAP and any potential beneficial design modifications, as set forth in
Part I of this Tariff.
Installed Capacity: Nameplate capacity adjusted for conditions at the site of installation.
International Power Marketing Entity: An entity that (i) owns, controls, purchases and/or sells resource adequacy supply and is responsible under the WRAP program for meeting LRE obligations associated with one or more loads physically located outside the United States.
Legacy Agreement: A power supply agreement entered into prior to October 1, 2021.
Load Charge: A component of the WRAP Administration Charge as established under Schedule 1 of this Tariff.
Load Charge Rate: Load Charge Rate shall have the meaning provided in Schedule 1 of this Tariff.
Load Services Costs: Load Services Costs shall have the meaning provided in Schedule 1 of this
Tariff.
Load Services Cost Centers: Load Services Cost Centers shall have the meaning provided in Schedule 1 of this Tariff.
Load Services Percentage: Load Services Percentage shall have the meaning provided in
Schedule 1 of this Tariff.
Load Responsible Entity (“LRE”): An LRE is an entity that (i) owns, controls, purchases and/or sells resource adequacy supply, or is a Federal Power Marketing Administration or an International Power Marketing Entity, and (ii) has full authority and capability, either through statute, rule, contract, or otherwise, to:
(a) submit capacity and system load data to the WRAP Program Operator at all hours;
(b) submit Interchange Schedules within the WRAP Region that are prepared in
accordance with all NERC and WECC requirements, including providing E-Tags

for all applicable energy delivery transactions pursuant to WECC practices and as
required by the rules of the WRAP Operations Program;
(c) procure and reserve transmission service rights in support of the requirements of
the WRAP Forward Showing Program and Operations Program; and
(d) track and bilaterally settle holdback and delivery transactions.
Subject to the above-mentioned criteria, an LRE may be a load serving entity, may act as an agent of a load serving entity or multiple load serving entities, or may otherwise be responsible for meeting LRE obligations under the WRAP.
Locational Marginal Price: The cost of delivering an additional unit of energy to a given node,
as calculated under a FERC-regulated wholesale electric tariff.
Loss of Load Expectation (“LOLE”): An expression of the frequency with which a single event of failure, due to resource inadequacy, to serve firm load would be expected (based on accepted reliability planning analysis methods) to result from a given FS Planning Reserve Margin.
Make Whole Adjustment: A component used as part of the calculation of settlements for
Holdback Requirements and Energy Deployments under Part III of this Tariff.
Maximum Base Charge: The maximum amount prescribed in Schedule 1 of the Tariff that the Base Charge cannot exceed.
Maximum Load Charge Rate: The maximum rate prescribed in Schedule 1 of the Tariff that the
Load Charge Rate cannot exceed.
Median Monthly P50 Peak Loads: Median Monthly P50 Peak Loads has the meaning prescribed by Schedule 1 of this Tariff.
Month: A calendar month.
Monthly Capacity Deficiency: A Participant’s Capacity Deficiency for a given Month.
Monthly Deficiency: An identification under Part II of this Tariff whether, and the extent to
which, a Participant’s need for capacity or transmission for a given Month is greater than the capacity or transmission, respectively, the Participant can demonstrate for such Month.
Monthly FS Capacity Requirement: FS Capacity Requirement determined as to a Month.
Monthly FSPRM: The FS Planning Reserve Margin applicable to a given Month of a given
Binding Season, as determined in accordance with Part II of this Tariff.
Monthly Transmission Deficiency: A Participant’s Transmission Deficiency for a given Month.
Monthly Transmission Demonstrated: A Participant’s Demonstrated FS Transmission for a given Month.

Monthly Transmission Exceptions: Exceptions from the FS Transmission Requirement
approved under Part II of this Tariff for a Participant for a given Month.
Multi-Day-Ahead Assessment: A period of days preceding each Operating Day, and ending on the Preschedule Day, during which Sharing Calculations are successively performed based in each case on Operating Day conditions expected at the time of calculation.
North American Electric Reliability Corporation (“NERC”): A not-for-profit international
regulatory authority that serves as the designated electric reliability organization for the continental
United States, Canada, and a portion of Mexico.
Net Contract QCC: The QCC, which may be a positive or negative value, calculated, in sum and on net, for a Participant’s power purchase agreements and power sale agreements, in accordance with Part II of this Tariff.
Non-Binding Season: As to a Participant, a Binding Season that occurs during the Transition
Period prior to the first Binding Season for which the Participant has elected to be subject to Parts II and III of this Tariff. Non-Binding Participant: For any Binding Season, a Participant that has made an election by
which such Binding Season is a Non-Binding Season for that Participant.
Open Access Transmission Tariff: A governing document on file with FERC establishing the rates, terms, and conditions of open access transmission service, or equivalent tariff of a transmission service provider that is not required to file its transmission service tariff with FERC.
Operating Day: A current Day of actual electric service from resources to load, for which Sharing
Events are determined and Energy Deployments may be required, as set forth in Part III of this Tariff.
P50 Peak Load Forecast: A peak load forecast prepared on a basis, such that the actual peak load is statistically expected to be as likely to be above the forecast as it is to be below the forecast.
Participant: A Load Responsible Entity that is a signatory to the WRAPA.
Portfolio QCC: As to a Participant, the sum of the Resource QCC provided by all of a Participant’s Qualifying Resources plus the Net Contract QCC of such Participant.
Preschedule Day: The applicable scheduling Day for a given Operating Day as defined in scheduling calendar established by WECC.
Program Administrator: The Western Power Pool, in its role as the entity responsible for
administering the WRAP.
Program Operator: A third party that has contracted with the Program Administrator to provide technical, analytical, and implementation support to the Program Administrator for the WRAP.

Program Review Committee (“PRC”): The stakeholder sector committee as established in
Section 4.2 of this Tariff.
Pure Capacity: A MW quantity of capacity without any assigned forced outage rate employed in ELCC determinations under Part II of this Tariff.
Qualifying Capacity Contribution (“QCC”): The MW quantity of capacity provided by a resource, contract, or portfolio which qualifies to help satisfy a Participant’s FS Capacity
Requirement, as determined in accordance with Part II of this Tariff.
Qualifying Resource: A generation or load resource that meets the qualification and accreditation requirements established by and under Part II of this Tariff.
Real-Time Price: A price for wholesale electric transactions designated as a real-time price in an Applicable Price Index.
Resource Adequacy Participant Committee (“RAPC”): The committee comprised of
representatives from each Participant as established in Part I of this Tariff.
Resource QCC: The QCC provided by a Qualifying Resource, as determined in accordance with Part II of this Tariff.
Run-of-River Qualifying Resource (“ROR”): A hydro-electric power project that does not have
the capability to store a sufficient volume of water to support continuous generation at the project’s
stated maximum capacity for a period of one hour. Resource does not meet the definition of a Storage Hydro Qualifying Resource.
Safety Margin: An additional factor allocated among Participants with positive sharing calculations when warranted by certain conditions as prescribed by Part III of this Tariff.
Senior Official Attestation: A signed statement of a senior official of a Participant attesting that
it has reviewed such Participant’s information submission required under this Tariff, that the statements therein are true, correct and complete to the best of such official’s knowledge and belief following due inquiry appropriate to the reliability and resource adequacy matters addressed therein, and containing such further statements as required by this Tariff or the applicable Business
Practice Manual for the information submission at issue.
Sharing Calculation: A calculation used in the Operations Program under Part III of this Tariff to identify any hour in which any Participant is forecast to have a capacity deficit.
Sharing Event: An hour or hours of an Operating Day for which one or more Participants has a negative Sharing Calculation result, as determined in accordance with Part III of this Tariff.
Sharing Requirement: A requirement applicable to a Participant with a positive Sharing
Calculation result for a given hour or hours of an Operating Day to potentially provide an Energy Deployment to a Participant with a negative Sharing Calculation result for those same hours, as determined in accordance with Part II of this Tariff.

Storage Hydro Qualifying Resource: A hydro-electric power project with an impoundment or
reservoir located immediately upstream of the powerhouse intake structures that can store a
sufficient volume of water to support continuous generation at the project’s stated maximum capacity for a period of one hour or longer.
Subregion: An area definition approved by the Board of Directors and identified in the Business Practice Manuals, that is wholly contained within the WRAP Region, which is separated from one
or more other Subregions by transmission constraints on capacity imports or on capacity exports
that result, or are expected to result, in differing FSPRM determinations for that Subregion relative to such other Subregion. Summer Season: A period of time that commences on June 1 of a Year and terminates on
September 15 of the same Year.
System Sale: A power sale in which the generation is sourced, at the seller’s discretion, from a group of two or more identified Qualifying Resources.
Transition Period: The Binding Seasons within the time period from June 1, 2025, through March 15, 2028, plus the time period required to implement the requirements and procedures of
Part II of this Tariff applicable to such Binding Seasons.
Transmission Deficiency: A shortfall in a Participant’s demonstration of secured transmission service rights, after accounting for any approved transmission exceptions, relative to that Participant’s FS Transmission Requirement, as further defined in Part II of this Tariff.
Unforced Capacity: The percentage of Installed Capacity available after a unit’s forced outage
rate is taken into account.
Variable Energy Resource (“VER”): An electric generation resource powered by a renewable energy source that cannot be stored by the facility owner or operator and that has variability that is beyond the control of the facility owner or operator, including but not limited to a solar or wind resource.
VER Zone: A geographic area delineated in accordance with Section 16.2.5.2 of this Tariff for a
given type of VER, where each VER of that type located in such area is anticipated to be comparably affected by meteorological or other expected conditions in such area to a degree that warrants distinct calculation of ELCC allocations for such VERs of that type in such area.
Western Electricity Coordinating Council (“WECC”): A non-profit corporation that has been
approved by FERC as the regional entity for the western interconnection and that also has NERC
delegated authority to create, monitor, and enforce reliability standards. Western Resource Adequacy Program Agreement (“WRAPA”): The participation agreement for the Western Resource Adequacy Program, as set forth as Attachment A to this Tariff, or as set
forth for an individual Participant in a non-conforming version of such participation agreement
accepted by FERC.

Western Resource Adequacy Program (“WRAP”): The Western Resource Adequacy Program,
as established under this Tariff.
Western Power Pool (“WPP”): Northwest Power Pool, d/b/a Western Power Pool, which serves as Program Administrator for the WRAP under this Tariff and holds exclusive rights under section 205 of the Federal Power Act to file amendments to this Tariff.
Winter Season: A period of time that commences on November 1 of a Year and terminates on
March 15 of the immediately following Year.
WRAP Cost Assignment Matrix: The matrix set forth in Schedule 1 of this Tariff to identify which WRAP costs are assessed to the Base Charge and the Load Charge components of the WRAP Administration Charge.
WRAP Region: The area comprising, collectively, (i) the duly recognized and established load
service areas of all loads in the United States that all Participants are responsible for serving, (ii)
the duly recognized and established load service areas of all loads in the United States that all load serving entities, on whose behalf a Participant acts in accordance with this Tariff, are responsible for serving, and (iii) the applicable location(s) on the United States side of the United States international border that form the basis for an International Power Marketing Entity’s participation
under the WRAP, in all cases excluding, for any Binding Season, any loads permitted by this Tariff
to be excluded from Participants’ Forward Showing Submittal for such Binding Season.
Year: A calendar year.

2. Role of Western Power Pool
2.1 WPP, acting under the direction of its Board of Directors, shall administer the
WRAP as Program Administrator. Except as specified in Section 3 of this Tariff, WPP, as authorized by its Board of Directors, shall have the sole authority to submit to FERC amendments to the rates, terms, and conditions set forth in this Tariff under section 205 of the Federal Power Act, 16 U.S.C. § 824d. Nothing contained
herein shall be construed as affecting in any way the right of any Participant or any
other entity to apply to FERC for amendments to the rates, terms, and conditions contained herein under section 206 of the Federal Power Act, 16 U.S.C. § 824e, or any other applicable provision of that Act.
2.1.1 WPP president and staff shall support the Board of Directors in overseeing
all aspects of the WRAP, including oversight and management of the
Program Operator(s) in accordance with any Program Operator agreement(s) entered into by WPP under Section 2.2 of this Tariff.
2.1.2 WPP and its staff shall provide all legal, regulatory, and accounting support for the WRAP, including support for making filings with FERC as
authorized by the Board of Directors.
2.1.3 WPP staff shall provide all logistical support necessary to facilitate implementation of the WRAP and specifically all logistical needs of the Board of Directors and reasonable logistical assistance to facilitate meetings and activities of the RAPC, PRC, and all subordinate organizational groups.
2.2 As Program Administrator, WPP shall undertake all actions as necessary to
implement and administer the WRAP, including but not limited to engaging one or more Program Operator(s) to perform technical operations of the WRAP including both the Forward Showing Program and Operations Program. Except as otherwise provided herein, WPP may contract for certain activities required by this Tariff to
be provided by one or more Program Operator(s) subject to oversight by the Board
of Directors, provided, however, that the Program Operator shall operate solely as a contractor under the oversight of WPP, and WPP shall remain the sole point of compliance with this Tariff. WPP shall have the sole authority to enter into contracts for such engagements and is responsible for providing support and
compensation for such Program Operator(s) pursuant to any contract(s).
2.2.1 WPP will contract with Program Operator(s) to assist WPP with providing reasonable technical support and expertise to all WRAP organizational groups as governed by the Program Operator’s contract with WPP.

3. Role of the Board of Directors and Limitations on Board Authority
3.1 Authority: Ultimate authority over all aspects of the WRAP as established under
this Tariff shall be vested in the independent Board of Directors. Each member of the Board of Directors shall at all times exhibit financial independence from all Participants and classes of Participants, as further provided in the WPP Bylaws and policies. As set forth in Section 2.1 of this Tariff, the Board of Directors shall have
the exclusive authority to approve and direct WPP to file amendments to this Tariff
with FERC under section 205 of the Federal Power Act, 16 U.S.C. § 824d, subject to the limitations and prohibitions imposed under Section 3.4 of this Tariff. The Board of Directors shall also have the exclusive authority to approve the Business Practice Manuals and any amendments to the Business Practice Manuals, subject
to the terms, conditions, and limitations imposed under this Tariff.
3.2 The Board of Directors generally shall meet in open session for all matters related to the WRAP; however, the Board of Directors may meet in closed session as the chair deems necessary to safeguard the confidentiality of sensitive information, including but not limited to discussing matters related to personnel, litigation, or
proprietary, confidential, or security sensitive information. The Board of Directors
shall not take action on any proposed amendment to this Tariff or the Business Practice Manuals in closed session. During open session, the chair of the Board of Directors will reasonably accommodate stakeholder requests to address the Board within the discretion of the chair.
3.3 The Board of Directors shall only consider amendments to this Tariff or the
Business Practice Manuals after such amendments are first acted upon by the RAPC, subject to the following additional conditions:
3.3.1 In the event that the RAPC has voted to reject or has not voted to support a proposed amendment to this Tariff or the Business Practice Manuals, any
stakeholder may appeal such decision to the Board of Directors, and the
Board of Directors shall consider the appeal.
3.3.2 In the event that the RAPC has voted to reject or has not voted to support a proposed amendment to this Tariff or the Business Practice Manuals and a stakeholder has not appealed such decision, the Board of Directors may, on
its own motion or motion of any member of the Board of Directors, consider
the proposed amendment.
3.3.3 In the event that the COSR as a body opposes or appeals a RAPC decision to the Board of Directors regarding an amendment to this Tariff or the Business Practice Manuals, the process set forth in Section 4.3.3 of this
Tariff shall apply prior to the Board of Directors’ consideration of the
RAPC decision.
3.3.4 In the event that the Board of Directors wishes to initiate an amendment to this Tariff or the Business Practice Manuals that has not undergone PRC

and RAPC review, the Board of Directors shall first submit such proposed
amendment to the PRC for review under the processes set forth in Sections
4.1 and 4.2 of this Tariff.
3.3.5 Expedited Review Process: In the event that the RAPC determines that an expedited review process is necessitated by an exigent circumstance as set forth in Section 4.1.3.1.1 of this Tariff, the Board of Directors shall review
the RAPC’s recommended Tariff or Business Practice Manual amendment
expeditiously and invite comment from the PRC, COSR, and stakeholders concurrently with its consideration of the RAPC proposal.
3.4 WPP is specifically prohibited from amending this Tariff to:
3.4.1 Alter, usurp, control, or otherwise materially modify the Participants’
existing functional control and responsibility over their generation and
transmission assets, including but not limited to planning and operation of such assets, Open Access Transmission Tariff administration, interfering with Balancing Authority duties and responsibilities, or imposing a must-offer requirement on any specific generation resources.
3.4.2 Administer Open Access Transmission Tariff service, engage in Balancing
Authority operations, impose transmission planning requirements, or assume any transmission planning responsibilities with regard to any of the Participant’s transmission assets.
3.4.3 Form any type of organized market, including but not limited to a capacity
market, a regional transmission organization, a real-time market, or any
other type of FERC-approved regional construct, unless such action is also approved by the RAPC under its voting procedures set forth in Section 4.1.6 of this Tariff.
3.4.4 Impose any requirements on Participants beyond the assessment of financial
charges as specified in this Tariff or suspension or termination of
participation for failure to meet any WRAP requirements.
3.4.5 Amend in any way this Section 3 of this Tariff without the approval of the RAPC under its voting procedures set forth in Section 4.1.6 of this Tariff.
3.4.6 Amend the RAPC voting thresholds set forth in Section 4.1.6 of this Tariff.
3.5 Subject to the limitations and prohibitions imposed under Section 3.4 of this Tariff,
if the Board of Directors votes to file at FERC to expand the WRAP to include market optimization or transmission planning services, WPP will initiate a formal process with COSR and other stakeholders to conduct a full review of governance structures and procedures, including the role of states. If COSR does not support
any revised governance structure that emerges from such WPP review process, the
WPP will file, along with any WPP governance proposal to FERC, an alternative

governance structure on behalf of the COSR so long as such COSR alternative
governance structure is supported by 75% of the COSR.

4. Organizational Groups for the WRAP
4.1 Resource Adequacy Participants Committee
4.1.1 Authority and Purpose: The RAPC shall be the highest level of authority for representation by Participants in the WRAP governance structure and shall represent the interests of Participants directly to the Board of Directors.
4.1.2 Composition: The RAPC shall be composed of one representative from
each Participant. Such representative shall be a senior management official with binding decision-making authority on behalf of the Participant, or a designated representative of a Participant’s senior management official. A designated representative shall be required to have binding decision-making
authority on behalf of the Participant and shall have all voting rights
delegated from the senior management official. Participant shall appoint a designated representative no less than one Business Day in advance of a meeting for that designated representative to be eligible to vote during the meeting.
4.1.3 Functions: The RAPC:
4.1.3.1 Shall consider and recommend that the Board of Directors approve or reject all proposed amendments to this Tariff or Business Practice Manuals prior to the Board of Directors considering such amendments, including any amendments reviewed and referred by
the PRC.
4.1.3.1.1 Exigent Circumstances: When the RAPC determines that an amendment to the Tariff or the Business Practice Manuals requires expedited Board of Directors review due to exigent circumstances, it may propose such
amendment directly to the Board of Directors without
awaiting review by other committees and stakeholders. Exigent circumstances include: (i) a FERC-mandated amendment to this Tariff or the Business Practice Manuals; (ii) an amendment to this Tariff or the Business Practice
Manuals to address an immediate reliability impact; or (iii)
an amendment to this Tariff or the Business Practice Manuals that the RAPC has determined has significant impacts to utility service.
4.1.3.2 Shall consider and vote to recommend that the Board of Directors
approve or reject any proposed amendments to this Tariff or the
Business Practice Manuals.
4.1.3.3 May provide input to the Board of Directors on any proposed WPP rules that apply both to the WRAP and other WPP services.

4.1.3.4 May evaluate and provide input to the Board of Directors on the
WRAP administration budget and budget allocation to Participants,
including amendments to the WRAP Administration Charge as calculated in accordance with Schedule 1 of this Tariff.
4.1.3.5 Shall form and organize all of the organizational groups under its responsibilities.
4.1.3.6 May take other actions reasonably related to its role as the senior-
level Participant advisory committee to the Board of Directors regarding WRAP matters.
4.1.4 Leadership: The RAPC shall select from among its members a chair and vice chair.
4.1.5 Meetings:
4.1.5.1 Meetings of the RAPC will generally be open to all stakeholders. WPP shall provide advanced written notice of the date, time, place, and purpose of each RAPC meeting. All RAPC decisional items shall be placed on the open meeting agenda and allotted adequate
time for public comment and deliberation.
4.1.5.1.1 The RAPC may meet in closed session as the RAPC chair deems necessary; provided, however, that the RAPC shall allow the designated COSR support staff member as specified in Section 4.3 of this Tariff to attend any closed
meeting. The RAPC shall not take action on any proposed
amendment to this Tariff or the Business Practice Manuals in closed session.
4.1.5.2 The quorum for a meeting of the RAPC or any organizational group organized under it shall be one-half of the representatives thereof,
but not less than three representatives, provided that a lesser number
may serve as a quorum for the sole purpose of voting to adjourn the meeting to a later time.
4.1.6 Voting:
4.1.6.1 Each RAPC representative shall have one vote.
4.1.6.2 Voting in the RAPC shall utilize a “House and Senate” model.
4.1.6.2.1 Each Participant’s “House” vote shall represent the proportion of the Participant’s Median Monthly P50 Peak Load, as described in Section 2 of Schedule 1 of this Tariff, compared to the sum of all Participants’ Median Monthly
P50 Peak Loads. A Participant may choose to divide its

House vote but is responsible for announcing such at the
time of voting.
4.1.6.2.2 Each Participant shall receive a single, non-weighted “Senate” vote.
4.1.6.2.3 For an action to be approved by the RAPC, it must pass both “House” and “Senate” votes as follows. For
purposes of voting, the percentages identified below specify
the percentage threshold of the entire RAPC (whether in attendance or not) that is needed for passage of an action.
4.1.6.2.3.1 Actions to amend any of the limitations on Board authority set forth in Section 3.4 of this Tariff
require an 80% affirmative approval by both the
House and the Senate vote tallies to be approved.
4.1.6.2.3.2 Actions brought before the RAPC that have been approved by the PRC require a 67% affirmative approval by both the House and Senate vote tallies to
be approved.
4.1.6.2.3.3 All other actions not specified in this Section 4.1.6.2.3 require a 75% affirmative approval by both the House and Senate vote tallies to be approved.
4.1.6.2.4 If at any time a single Participant’s P50 load for
voting purposes would result in that Participant possessing a
veto over any votes taken under Section 4.1.5.2.3, such Participant’s House vote shall be capped at 1% below the amount that would convey such a veto, such that no single Participant will possess a veto over any action taken under
Section 4.1.6.2.3.
4.2 Program Review Committee
4.2.1 Authority and Purpose: The PRC is a sector-representative group comprised in accordance with Section 4.2.2 of this Tariff. The PRC is responsible for receiving, considering, and proposing amendments to this
Tariff and the Business Practice Manuals. The PRC shall serve as a
clearinghouse of all recommended amendments to this Tariff or the Business Practice Manuals, except for those designated by the RAPC as involving an exigent circumstance under Section 4.1.3.1.1 of this Tariff, amendments to Schedule 1 of this Tariff and cost allocation for the WRAP,
and amendments to the WRAPA set forth as Attachment A of this Tariff.
The PRC shall serve in an advisory capacity to the RAPC and, when applicable, the Board of Directors.

4.2.1.1 The PRC shall present all proposals received to the RAPC, along
with the PRC’s recommendation and summaries of all comments
and feedback received.
4.2.1.2 The PRC’s decisions are advisory-only and are not binding on the RAPC, the Board of Directors, or WPP.
4.2.2 Composition: The PRC shall be composed of up to twenty representatives
from the following ten sectors: four representatives of RAPC Participant
investor-owned utilities; four representatives of RAPC Participant publicly-owned (consumer or municipal) utilities; two representatives of RAPC Participant retail competition load serving entities; two representatives from RAPC Participant Federal Power Marketing Administrations; two
representatives of independent power producers; two representatives of
public interest organizations; one representative of retail consumer advocacy groups; one representative of industrial customer advocacy groups; one representative of load serving entities with loads in the WRAP that are represented by other LREs and are not otherwise eligible for any
other sector; a representative from the COSR. Expectations for sectors to
consider regional, operational, geographic, demographic, and other forms of diversity in selecting their sector representatives are set forth in more detail in the PRC charter, which shall be posted and maintained on the WRAP website or other appropriate public location.
4.2.3 The PRC shall establish a process and criteria for receiving and reviewing
proposed amendments to this Tariff and the Business Practice Manuals. Such review will include procedures for stakeholder comment.
4.2.4 Meetings: The PRC shall meet primarily in open session; provided that the PRC may schedule closed meetings if it determines that doing so would be
beneficial to safeguard the confidentiality of sensitive information. The
PRC shall not take action on any proposed amendment to this Tariff or the Business Practice Manuals in closed session.
4.2.5 Voting: The PRC shall endeavor to operate by consensus. When voting is necessary, voting shall consist of one sector one vote, with an affirmative
vote of six sectors (as specified in Section 4.2.2 of this Tariff) constituting
approval of an action before the PRC.
4.2.5.1 For sectors with four seats, three sector representatives must agree with the action for the sector to be considered an affirmative vote for the action.
4.2.5.2 For sectors with two seats, both sector representatives must agree
with the action for the sector to be considered an affirmative vote for the action.

4.2.6 Participants and other entities shall participate in no more than one PRC
sector. If a Participant or other entity is eligible to participate in more than
one sector, such Participant or other entity shall declare in which sector it will participate.
4.3 Committee of State Representatives
4.3.1. Composition: The COSR is a committee composed of one representative
from each state or provincial jurisdiction (either public utility commission
or state/provincial energy office) that regulates at least one Participant.
4.3.2 Leadership: The COSR shall determine its leadership, including a chair and vice chair. The chair or vice chair will be requested to attend all open sessions of the RAPC to provide input and advice.
4.3.2.1 The COSR shall designate a COSR support staff member to attend
and audit closed meetings of the RAPC under a non-disclosure agreement.
4.3.3 Authority:
4.3.3.1 If the COSR determines that a proposal approved by the RAPC is
substantially different from the proposal submitted to the RAPC by
the PRC, the COSR may engage in additional public review and comment before the RAPC decision is presented to the Board of Directors; provided that this additional public review and comment does not unreasonably delay presentation to the Board of Directors.
4.3.3.2 If the COSR as a body opposes or appeals a RAPC decision to the
Board of Directors, the Board of Directors will not consider the RAPC’s decision until the RAPC engages with the COSR to discuss, in at least two public discussions, to attempt to reach a mutually agreeable solution.
4.3.3.2.1 If the appeal relates to an amendment that the RAPC
designated as involving an exigent circumstance under Section 4.1.3.1.1 of this Tariff, COSR can require no more than one public discussion, provided that such additional discussion does not unreasonably hinder the timeline for
Board of Directors consideration of the proposed
amendment.
4.3.4 Voting, Meetings, and Quorum: The COSR may develop its own rules governing voting, meetings, and quorum for action. COSR shall be responsible for its own costs.

5. Independent Evaluator
5.1 WPP shall engage an Independent Evaluator to provide an independent
assessment of the performance of the WRAP and any potential beneficial design
modifications. The Independent Evaluator shall report directly to the Board of
Directors.
5.2 The Independent Evaluator shall conduct an annual review of the WRAP,
including but not limited to analyzing prior year program performance,
accounting and settlement, and program design.
5.3 The Independent Evaluator shall prepare an annual report of its findings, and any
recommended modifications to WRAP design, and present its findings to the
WRAP committees and the Board of Directors, subject to any necessary
confidentiality considerations. Any data included in the Independent Evaluator’s
report shall be reported on an aggregated basis as applicable to preserve
confidentiality. The Independent Evaluator's annual reports shall be available to
the public, except to the extent they contain information designated as
confidential under this Tariff, or information designated as confidential by the
Independent Evaluator.
5.4 The Independent Evaluator shall not:
5.4.1 Evaluate individual Participants.
5.4.2 Possess any decision-making authority regarding the WRAP or design
modifications.
5.4.3 Evaluate WPP’s day-to-day operations of the WRAP (except as part of
review of prior year program performance).

6. WPP Invoicing and Settlement
6.1 WPP shall be responsible for issuing invoices to, and collecting from, Participants
all charges under Schedule 1 of this Tariff for recovery of all WPP costs associated with administering the WRAP.
6.2 WPP shall be responsible for invoicing, collecting, and (as applicable) distributing revenues from Deficiency Charges under Part II of this Tariff and Delivery Failure
Charges under Part III of this Tariff.
6.3 Participants are not required to provide credit assurances to WPP to cover charges under Schedule 1 of this Tariff, Deficiency Charges under Part II of this Tariff, or Delivery Failure Charge under Part III of this Tariff.
6.4 Participants shall make full payment of all invoices rendered by WPP for which
payment is required to WPP within thirty calendar days following the receipt of the
WPP invoice, notwithstanding any disputed amount, but any such payment shall not be deemed a waiver of any right with respect to such dispute. Any Participant that fails to make full and timely payment to WPP of amounts owed upon expiration of the cure period specified in Section 6.4.1 of this Tariff will be in default.
6.4.1 If a Participant fails to make timely payment as required by Section 6.4,
WPP shall so notify such Participant. The notified Participant may remedy such asserted breach by paying all amounts due, along with interest on such amounts calculated in accordance with the methodology specified for interest on refunds in FERC’s regulations at 18 C.F.R. § 35.19a(a)(2)(iii);
provided, however, that any such payment may be subject to a reservation
of rights, if any, to refer such matter to dispute resolution procedures under Section 9 of this Tariff. If the Participant has not remedied such asserted breach by 5:00 p.m. Pacific Prevailing Time on the second Business Day following WPP’s issuance of a written notice of breach, then the Participant
shall be in default.
6.4.2 In the event of a Participant’s default under Section 6.4.1 of this Tariff, WPP in its discretion may pursue collection through such actions, legal or otherwise, as it reasonably deems appropriate, including but not limited to
the prosecution of legal actions and assertion of claims in the state and
federal courts as well as under the United States Bankruptcy Code. After deducting any costs associated with pursuing such claims, any amounts recovered by WPP with respect to defaults for which there was a Default Allocation Assessment shall be distributed to the Participants who have paid
their Default Allocation Assessment in proportion to the Default Allocation
Assessment paid by each Participant, as calculated pursuant to Section 6.4.3 of this Tariff. In addition to any amounts in default, the defaulting Participant shall be liable to WPP for all reasonable costs incurred in enforcing the defaulting Participant’s obligations.

6.4.3 In the event of a Participant’s default with respect to an invoice issued by
WPP for charges under Schedule 1 of this Tariff, in order to ensure that
WPP remains revenue neutral, the Board of Directors may assess against, and collect from, the Participants not in default a Default Allocation Assessment to recover the costs associated with the default. Such assessment shall in no way relieve the defaulting Participant of its
obligations.
6.4.3.1 The Default Allocation Assessment shall be equal to: (20% × (1/N) + (80% × (Participant Median Monthly P50 Peak Load / Sum Participants Median Monthly P50 Peak
Load) where:
N = the total number of Participants, calculated as of the date
WPP declares a Participant in default. Participant Median Monthly P50 Peak Load = for each Participant included in factor “N” above, the Participant’s
Median Monthly P50 Peak Load as determined in Section 2 of
Schedule 1 of this Tariff, recalculated on the day the WPP declares a Participant in default. All Participants Median Monthly P50 Peak Load = the sum of
the Participant Median Monthly P50 Peak Load values for all
Participants included in factor “N” above.

7. Credit Requirements and Settlement for Holdback and Delivered Energy
7.1 Credit and Settlement for Holdback and Delivered Energy: Settlement of holdback
and delivered energy shall be completed bilaterally between Participants, subject to the following:
7.1.1 Neither WPP nor the Program Operator(s) shall take title to energy or be party to any settlement of holdback or delivered energy.

7.1.2 Participants shall establish credit with each other through one of the following mechanisms. Neither WPP nor the Program Operator(s) shall be involved in the calculation of credit or credit limits.
7.1.2.1 Establish credit directly with each Participant: Participants may
establish credit directly with other Participants from whom they may receive delivered energy. 7.1.2.1.1 Such credit should be established in advance of the
applicable season.
7.1.2.1.2 The amount of such credit and any credit limit shall be at the discretion of each Participant.
7.1.2.2 WPP shall conduct a competitive solicitation process to identify a third-party service provider to serve as central credit organization
and clearing house for credit and settlement. Once such central
credit organization is selected, Participants that have not already directly established credit with all other Participants under Section 7.2.2.1 of this Tariff shall establish credit with the central credit organization.

7.1.2.2.1 WPP will provide the central credit organization any Operations Program related information necessary for them to perform their obligations as set forth in the agreement between WPP and the central credit organization.
7.1.2.2.2 All costs associated with the central credit
organization service shall be borne by Participants as established in the agreement between WPP and the central credit organization and either billed directly on a transactional basis or else recovered under Schedule 1 of this
Tariff.
7.1.2.3 The obligation to arrange sufficient credit shall at all times be on the deficient Participant (i.e., a Participant with a negative sharing calculation in the Operations Program). If a deficient Participant has not made good faith and commercially reasonable efforts to

obtain sufficient credit with a delivering Participant, such delivering
Participant shall so notify WPP and shall be excused from any
obligation to deliver to such deficient Participant. Nothing in this Section 7 requires a Participant to violate its written risk or credit policy.

8. Force Majeure, Limitation of Liability, and Indemnification
8.1 Force Majeure: An event of Force Majeure means any act of God, labor
disturbance, act of the public enemy, war, insurrection, riot, pandemic, fire, storm or flood, explosion, breakage or accident to machinery or equipment, any order, regulation, or restriction imposed by governmental military or lawfully established civilian authorities, or any other cause beyond a party’s control. A Force Majeure
event does not include an act of negligence or intentional wrongdoing. Neither
WPP nor the Participant will be considered in default as to any obligation under this Tariff if prevented from fulfilling the obligation due to an event of Force Majeure. However, a Party whose performance under this Tariff is hindered by an event of Force Majeure shall make all reasonable efforts to perform its obligations
under this Tariff. Notwithstanding the foregoing, the physical inability to perform
because of an event of Force Majeure shall not relieve the party of any financial obligations incurred under this Tariff or as a result of the Force Majeure event, unless, and to the extent, such financial obligation is waived or excused under provisions of Part II or Part III of this Tariff expressly providing for such waiver or
excuse.
8.2 Limitation of Liability:
8.2.1 Neither WPP nor the Program Operator shall be liable, whether based on contract, indemnification, warranty, tort, strict liability or otherwise, to any Participant, other entity owning a Qualifying Resource, third party, or other
person for any damages whatsoever, including, without limitation, direct,
incidental, consequential, punitive, special, exemplary, or indirect damages arising or resulting from any act or omission in any way associated with service provided under this Tariff or any agreement hereunder, including, but not limited to, any act or omission that results in an interruption,
deficiency or imperfection of service, except to the extent that the damages
are direct damages that arise or result from the gross negligence or intentional misconduct of WPP or Program Operator, in which case WPP shall only be liable for direct damages.
8.2.2 Neither WPP nor the Program Operator shall be liable for damages arising
out of services provided under this Tariff or any agreement entered into
hereunder, including, but not limited to, any act or omission that results in an interruption, deficiency, or imperfection of service, occurring as a result of conditions or circumstances beyond the control of WPP, or resulting from electric system design common to the domestic electric utility industry or
electric system operation practices or conditions common to the domestic
electric utility industry.
8.2.3 To the extent that a Participant or other person has a claim against WPP, the amount of any judgment or arbitration award on such claim entered in favor of such entity shall be limited to the value of WPP’s assets. No party may
seek to enforce any claims under this Tariff or any Agreements entered into

hereunder against the directors, managers, members, shareholders, officers,
employees, or agents of WPP, or against the Program Operator, who shall
have no personal liability for obligations of WPP by reason of their status as directors, managers, members, shareholders, officers, employees, or agents of WPP or by virtue of their status as Program Operator.
8.2.4 To the extent that WPP is required to pay any money damages or
compensation or pay amounts due to its indemnification of any other party
as it relates to any services provided, acts, or omissions under this Tariff or any agreement entered into hereunder, WPP shall be allowed to recover any such amounts under Schedule 1 of this Tariff as part of the WRAP Administration Charge. Notwithstanding the foregoing, WPP shall be
prohibited from recovering under this Tariff any costs associated with any
damages, compensation, or indemnification costs that arise: (i) with regard to any acts or omissions that occur outside of this Tariff and any agreements entered into hereunder, or (ii) if a court of competent jurisdiction determines that the damages are direct damages that arise or result from the gross
negligence or intentional misconduct of WPP or the Program Operator.
8.2.5 A Participant's liability to another Participant under this Tariff for failure to comply with obligations under this Tariff shall be limited to any charges or payments calculated pursuant to this Tariff; provided, however, that nothing in this Section 8.2.5 shall limit or is intended to foreclose any Participant's
liability that may arise under any bilateral agreements between Participants.
8.3 Indemnification: The Participants shall at all times indemnify, defend, and save WPP (and any of its Program Operator(s), agents, consultants, directors, officers, or employees) harmless from any and all damages, losses, claims, including claims and actions relating to injury to or death of any person or damage to property,
demands, suits, recoveries, costs and expenses, court costs, attorney fees, and all
other obligations by or to third parties arising out of or resulting from the performance of activities under this Tariff by WPP, any Program Operator(s), or agents, consultants, directors, officers, or employees of WPP, except in cases of gross negligence or intentional wrongdoing by WPP or the Program Operator.
WPP shall credit any proceeds from insurance or otherwise recovered from third
parties to Participants who have paid to indemnify WPP under this Section 8.3.
8.4 Actions upon Unavailability of Program Operator(s): In the event that the Program Operator(s) become(s) unwilling, unable, or otherwise unavailable to perform contractual duties necessary for WPP to discharge its obligations under this Tariff
and WPP’s agreement(s) with the Program Operator(s), WPP shall engage with
Participants as soon as practicable to determine what actions to take, including but not limited to filing with FERC a request to waive one or more provisions of this Tariff up to and including immediate suspension of all rights and obligations under this Tariff until a replacement Program Operator(s) can assume all relevant
Program Operator functions.

9. Dispute Resolution Procedures
9.1 Internal Dispute Resolution Procedures: Any dispute between a Participant and
WPP under the Tariff (excluding amendments to the Tariff or to any agreement entered into under the Tariff, which shall be presented directly to the FERC for resolution) shall be referred to a designated senior representative of WPP and a senior representative of the Participant for resolution on an informal basis as
promptly as practicable. In the event the designated representatives are unable to
resolve the dispute within thirty days (or such other period as the parties may agree upon) by mutual agreement, such dispute shall then be referred to the chief executive officer or comparable executive of each party for resolution. In the event that the executives are unable to resolve the dispute within thirty days (or such other
period as the parties may agree upon), such dispute may be submitted to arbitration
and resolved in accordance with the arbitration procedures set forth below.
9.2 External Arbitration Procedures: Any arbitration initiated under the Tariff shall be conducted before a single neutral arbitrator appointed by the parties to the dispute. If the parties fail to agree upon a single arbitrator within ten days of the referral of
the dispute to arbitration, each party shall choose one arbitrator who shall sit on a
three-member arbitration panel. The two arbitrators so chosen shall within twenty days select a third arbitrator to chair the arbitration panel. In either case, the arbitrators shall be knowledgeable in electric utility matters, including electric transmission and bulk power issues, and shall not have any current or past
substantial business or financial relationships with any party to the arbitration
(except prior arbitration). The arbitrator(s) shall provide each of the parties an opportunity to be heard and, except as otherwise provided herein, shall generally conduct the arbitration in accordance with the Commercial Arbitration Rules of the American Arbitration Association and any applicable FERC regulations.
9.3 Arbitration Decisions: Unless otherwise agreed by the parties, the arbitrator(s)
shall render a decision within ninety days of appointment and shall notify the parties in writing of such decision and the reasons therefor. The arbitrator(s) shall be authorized only to interpret and apply the provisions of the Tariff and/or any agreement entered into under the Tariff and shall have no power to modify or
change any of the above in any manner. The decision of the arbitrator(s) shall be
final and binding upon the Parties, and judgment on the award may be entered in any court having jurisdiction. The decision of the arbitrator(s) may be appealed solely on the grounds that the conduct of the arbitrator(s), or the decision itself, violated the standards set forth in the Federal Arbitration Act and/or the
Administrative Dispute Resolution Act. The final decision of the arbitrator must
also be filed with the FERC if it affects jurisdictional rates, terms and conditions of service or facilities.
9.4 Costs: Each party shall be responsible for its own costs incurred during the arbitration process and for the following costs, if applicable: (i) the cost of the
arbitrator chosen by the party to sit on the three-member panel and one half of the

cost of the third arbitrator chosen; or (ii) one half the cost of the single arbitrator
jointly chosen by the Parties.
9.5 Rights Under the Federal Power Act: Nothing in this section shall restrict the rights of any person to file a complaint with the FERC under relevant provisions of the Federal Power Act or of WPP to file amendments to this Tariff under the relevant provisions of the Federal Power Act.

10. Treatment of Confidential and Commercially Sensitive Information of Participants
10.1 Terms: For purposes of this Section 10 only, the term “WPP” shall also include, as
applicable, any directors, officers, employees, agents, or consultants of WPP, the Independent Evaluator established under Section 5 of this Tariff, and any central credit organization established under Section 7 of this Tariff. WPP shall be bound by the rights, obligations, and conditions set forth in this Section 10. For purposes
of this Section 10, the term “Disclosing Entity” shall include any Participant that
discloses information to WPP that the Disclosing Entity deems and identifies as confidential or commercially sensitive. WPP’s collection and handling of non-Participant data shall be governed by separate non-disclosure agreements with such non-Participants.
10.2 Treatment of Confidential or Commercially Sensitive Information: WPP shall
maintain the confidentiality of all of the documents, data, and information provided to it by any Participant that such disclosing Participant deems and specifically identifies as confidential or commercially sensitive; provided, however, that WPP need not keep confidential: (i) information that is publicly available or otherwise
in the public domain; or (ii) information that is required to be disclosed under this
Tariff or any applicable legal or regulatory requirement (subject to the procedures set forth in Section 10.4 of this Tariff).
10.2.1 WPP staff may develop and release publicly composite or aggregated data based upon Participant confidential or commercially sensitive information,
provided that such composite or aggregated data cannot be used to identify
or attribute a disclosing Participant’s confidential or commercially sensitive data. Such release of composite or aggregated data shall be governed by the following process.
10.2.1.1 Prior to the initial release of such composite or aggregated
data, WPP staff shall present the form and format of such
data to each Participant whose confidential information or data will be used to create the composite or aggregated data. If any such Participant objects to the form and format as revealing or allowing for attribution of confidential or
commercially sensitive Participant-specific data, WPP staff
shall determine whether to modify the form and format or to retain the proposed form and format for release. If WPP staff elects to retain the proposed form and format, the Participant shall have the right to appeal to the RAPC and WPP staff
shall be prohibited from releasing the composite or
aggregated data in the proposed form and format until the Participant’s appeal rights as specified in this Section 10.2.1 are exhausted.
10.2.1.2 If a Participant appeals a WPP staff decision regarding the
form and format of composite or aggregated data to the

RAPC, the RAPC shall consider whether the form and
format reveals or allows for attribution of confidential or
commercially sensitive Participant-specific data. If the RAPC determines that the proposed form and format is sufficient to protect against the release of confidential or commercially sensitive Participant-specific data, WPP staff
is authorized to release the composite or aggregated data in
the proposed form and format unless the Participant timely appeals the RAPC decision to the Board of Directors.
10.2.1.3 If a Participant appeals a RAPC decision regarding the form and format of composite or aggregated data to the Board of
Directors, the Board of Directors shall consider whether the
form and format is sufficient to protect against the release or attribution of confidential or commercially sensitive Participant-specific data. If the Board of Directors determines that the proposed form and format is sufficient to
protect against the release of confidential or commercially
sensitive Participant-specific data, WPP staff is authorized to release the composite or aggregated data in the proposed form and format.
10.2.1.4 Once a proposed form and format of composite or
aggregated data is approved by the WPP staff and is not
appealed or appeals are unsuccessful, such form and format may be used for all future disclosures of composite or aggregate information and no Participant may dispute such release. If WPP staff proposes to alter the form and format,
including but not limited to changing the granularity of data,
WPP staff shall be required to follow the process set forth in this Section 10.2.1 and Participants shall have the right to appeal such changes in form and format as set forth herein. Notwithstanding the foregoing, if the composition of
Participants in the WRAP changes in such a way that the
form and format of composite or aggregated data is no longer sufficient to protect against disclosure or attribution of confidential or commercially sensitive Participant-specific data, an aggrieved Participant shall have a one-time right to
raise the issue promptly with WPP Staff for presentation to
and review by the Board of Directors, and the Board of Directors in its sole discretion shall decide whether the change in composition results in the form and format of the composite or aggregated data becoming insufficient to
protect against the release or attribution of confidential or
commercially sensitive Participant-specific data; provided, however, that if an aggrieved Participant does not raise its concerns with the Board of Directors promptly following the

change in composition, such Participant shall have waived
its right to contest the release of such composite or
aggregated data.
10.2.2 Notwithstanding anything to the contrary in this Section 10.2, if the RAPC unanimously votes to disclose publicly any particular category of Participant-specific data, such data shall no longer be deemed confidential
regardless of any such designation by a disclosing Participant, and this
election shall be binding on any current and future Participants until such time as the RAPC votes unanimously to prohibit public release of such category of data. A list of the categories of Participant-specific data that the RAPC unanimously votes to make public shall be included in the Business
Practice Manuals.
10.3 Access to Confidential or Commercially Sensitive Information: Except as otherwise provided in Section 10.2 of this Tariff, no Participant, entity owning a Qualifying Resource, or any third party shall have the right hereunder to receive from WPP or to otherwise obtain access to any documents, data or other
information that has been identified as or deemed to be confidential or
commercially sensitive under Section 10.2 of this Tariff by a disclosing Participant. The provisions of this Section 10.3 do not apply to WPP (including any Independent Evaluator, member of the Board of Directors, or any WPP officer, employee, agent, or consultant that requires access to confidential or commercially
sensitive information); provided that access to Participant-specific confidential or
commercially sensitive information shall be solely for the purpose of performing the duties or functions under this Tariff or otherwise advising or assisting WPP. WPP shall develop internal policies and controls governing the handling and protection of confidential or commercially sensitive Participant-specific data by
members of the Board of Directors, officers, employees, agents, consultants, or any
Independent Evaluator.
10.4 Exceptions: Notwithstanding anything in this Section 10 to the contrary:
10.4.1 If WPP is required by applicable laws or regulations, or in the course of administrative or judicial proceedings, to disclose information that is
otherwise required to be maintained in confidence pursuant to this Section
10, WPP may disclose such information; provided, however, that as soon as practicable after WPP learns of the disclosure requirement and prior to making such disclosure, WPP shall notify any affected disclosing Participant of the requirement and the terms thereof. Any such disclosing
Participant may, at its sole discretion and own cost, direct any challenge to
or defense against the disclosure requirement and WPP shall cooperate with such disclosing Participant to take all reasonable available steps to oppose or otherwise minimize the disclosure of the information permitted by applicable legal and regulatory requirements. WPP shall further cooperate
with such disclosing Participant to the extent reasonably practicable to
obtain proprietary or confidential treatment of confidential or commercially

sensitive information by the person to whom such information is disclosed
prior to any such compelled disclosure.
10.4.2 WPP may disclose confidential or commercially sensitive information, without notice to any affected disclosing Participant(s), in the event that FERC, during the course of an investigation or otherwise, requests information that is confidential or commercially sensitive. In providing the
information to FERC, WPP shall take action, consistent with 18 C.F.R. §§
1b.20 and/or 388.112, to request that the information be treated by FERC as confidential and non-public and, if appropriate, as Critical Energy Infrastructure Information and that the information be withheld from public disclosure. WPP shall provide the requested information to FERC within
the time provided for in the request for information. WPP shall notify any
affected disclosing Participant(s) within a reasonable time after WPP is notified by FERC that a request for disclosure of, or decision to disclose, the confidential or commercially sensitive information has been received, at which time WPP and any affected disclosing Participant may respond
before such information would be made public.
10.5 Notwithstanding any efforts undertaken pursuant to Section 10.4 to prevent or limit the release of a Participant’s confidential or commercially sensitive information, in the event that FERC or a court of competent jurisdiction orders or otherwise permits the public release of a Participant’s confidential or commercially sensitive
information, the affected Participant shall have a one-time right to elect to terminate
its participation in the WRAP under the expedited termination provisions set out in Section 11.2 of the WRAPA.
10.6 WPP shall handle any information identified or deemed to be Controlled Unclassified Information/Critical Energy Infrastructure Information in accordance
with FERC’s regulations set forth at 18 C.F.R. § 388.113 and any applicable FERC
policies or other regulations, including but not limited to restricting access to such information on a password-protected portion of WPP’s website or similar precautions.
10.7 Nothing in this Section 10 is intended to limit a Participant’s ability to disclose or
release publicly its own confidential or commercially sensitive information or data,
or to limit a Participant’s ability to authorize WPP’s disclosure of such material to a specified recipient.

11. Timing
11.1 In the event that any deadline specified in this Tariff shall fall on a day that is not a
Business Day, the deadline shall be extended to the next Business Day.

12. Application and Registration
12.1 Any entity wishing to participate in the WRAP must submit an application and
registration in accordance with the Business Practices Manuals and must execute the WRAPA as set forth in Attachment A of this Tariff, or a non-conforming version of such participation agreement that is approved by FERC for an individual Participant. Such application and registration must be submitted in
accordance with the timelines set forth in the Business Practices Manuals in
advance of the next Binding Season.
12.2 Each Participant must register all of its resources and loads, regardless of whether such resources will be used to satisfy the WRAP requirements and regardless of whether certain loads will be subject to the requirements of the WRAP. Participants
may modify their registration of resources and loads in accordance with the timing
procedures set forth in the Business Practices Manuals.
12.3 In the event that more than one Participant attempts to register the same resource or load, the following procedure will be used to assign the resource or load to a Participant:
12.3.1 If a Participant attempts to register a load or resource that has already been
registered by a different Participant, the resource or load will remain registered by the original Participant registering the resource or load until such time as both Participants mutually inform WPP that a change to the registration is required.
12.3.2 If two or more Participants attempt to register the same resource or load
during the same registration window, WPP shall request that the Participants determine among themselves the appropriate registration of the resource or load before that resource or load is included in the WRAP.

PART II FORWARD SHOWING PROGRAM

13. Overview
13.1 In the Forward Showing Program, as set forth in this Part II of the Tariff, and as
further detailed in the Business Practice Manuals, each Participant shall, in advance of each Binding Season, show as to such Binding Season: (i) the total capacity, referred to and defined herein as the FS Capacity Requirement, required by the provisions of this Tariff for such Binding Season for reliable service to the loads
for which such Participant is responsible; (ii) the demonstration of capacity,
referred to and defined herein as the Qualifying Capacity Contribution, or QCC, provided by the Qualifying Resources the Participant provides or procures to meet its FS Capacity Requirement; and (iii) at least the minimum level of firm transmission service, referred to and defined herein as the FS Transmission
Requirement, needed for reliable delivery of the QCC of the Participant’s
Qualifying Resources from such resources to the loads for which the Participant is responsible.
13.2 As also set forth in this Part II of the Tariff, and as further detailed in the Business Practice Manuals: (i) WPP shall, in advance of each Binding Season, review the
Forward Showing Submittals of each Participant for such Binding Season; (ii) WPP
shall identify to the Participant any deficiencies in the Participant’s Portfolio QCC (whether as to contracts or directly owned or controlled resources) relative to the FS Capacity Requirement, and any deficiencies in the identified firm transmission service relative to the FS Transmission Requirement, within sixty days of the
Forward Showing Submittal deadline; (iii) the Participant shall have an opportunity
to cure such deficiencies, within sixty days of notification of deficiency; and (iv) if the Participant fails to cure all such deficiencies on or before the deadlines prescribed herein, the Participant shall be assessed a Forward Showing Deficiency Charge.

14. Forward Showing Program Process and Timeline
14.1 The Forward Showing Program has two Binding Seasons, defined as the Summer
Season and the Winter Season. The Summer Season is the period beginning on June 1 of each Year and ending on September 15 of that same Year. The Winter Season is the period beginning on November 1 of each Year and ending on March 15 of the succeeding Year. This Tariff does not establish resource or showing
obligations outside the periods defined by the Summer Season and Winter Season.
14.2 Each Participant shall submit its Forward Showing Submittals for each Month of each Binding Season, with all required supporting materials and information as detailed in the Business Practice Manuals, on or before the FS Deadline for the Binding Season. The FS Deadline for each Binding Season shall be seven months
before the start of such Binding Season.
14.2.1 Forward Showing Submittal:
14.2.1.1 Absent the exception in Section 14.2.1.2, each Participant shall submit a separate Forward Showing Submittal for loads for which it is responsible if transmission constraints between areas
where its loads are located, including, without limitation, when
Participant is responsible for loads in more than one Subregion, prevent application, in the manner more fully described in the Business Practice Manuals, of Resource QCC or Net Contract QCC from one load area to the FS Capacity Requirement of another load
area.
14.2.1.2 Notwithstanding Section 14.2.1.1, a Participant responsible for loads in two Subregions may submit for a given Month a single Forward Showing Submittal for such loads, and may employ for determination of its FS Capacity Requirement for such Month the
lower of the two FSPRM values determined for the Subregions
where its loads are located, if the Participant demonstrates in such Forward Showing Submittal, in accordance with the procedures and requirements set forth in the Business Practice Manuals, transmission service rights, which such Participant will make
available during all hours of such Month for purposes of regional
diversity sharing under the WRAP, of the type required by the FS Transmission Requirement, in a quantity, in addition to that required by the FS Transmission Requirement, equal to the difference in the two FSPRM values multiplied by the Participant’s P50 Peak Load
Forecast for such Month, with the a point of delivery in the
Subregion with the higher FSPRM value and the point of receipt in the Subregion with the lower FSPRM value. Each such offer shall identify the MW quantity, Month of service, point of receipt, and point of delivery of such transmission service rights, and such other
information as specified in the Business Practice Manuals, and shall

verify that the offered rights are NERC Priority 6 or NERC Priority
7 firm point-to-point transmission service. No Participant is
obligated to offer any such transmission service rights, but any offer so made and not withdrawn before the deadline specified in the Business Practice Manuals shall be considered a binding offer of the identified transmission service rights which may not be withdrawn
before the end of the last Day of the Month for which such
transmission service is offered.
14.2.2 Each Participant’s Forward Showing Submittal shall include a Senior Official Attestation.
14.3 The FSPRM values used in the Forward Showing Submittals for a Binding Season
shall be those values approved by the Board of Directors as the culmination of an
Advance Assessment process. No later than twelve months before the FS Deadline for each Binding Season, WPP will determine and post the recommended FSPRM for each Subregion for each Month of such Binding Season. Participants shall provide their load, resource and other information reasonably required to perform
the analyses and calculations required for the Advance Assessment, in accordance
with the Advance Assessment information submission details and schedule specified in the Business Practice Manuals. No later than nine months before the FS Deadline for such Binding Season, the Board of Directors shall take its final action regarding approval of the FSPRM values for each Month of such Binding
Season.
14.3.1 In connection with an Advance Assessment process, or otherwise in connection with consideration of a change to the Business Practice Manuals, the Board of Directors may determine that designation of Subregions would encourage the relief, in whole or part, of transmission
constraints on the transfer of capacity within the WRAP Region (whether
through development or commitment of transmission, of Qualifying Resources, or by other means) to the benefit of the WRAP Region and the advancement of the objectives of the WRAP. Each such Subregion shall be identified in the Business Practice Manuals.
14.3.2 Any Participant may choose to offer in the Advance Assessment process
transmission service rights owned or controlled by such Participant for firm delivery of capacity from one Subregion to another Subregion, for use by other Participants under the terms of Part III of this Tariff during any or all identified Months of the applicable Binding Season. Each such offer shall
identify the MW quantity, Month of service, point of receipt, and point of
delivery of such transmission service rights, and such other information as specified in the Business Practice Manuals, and shall verify that the offered rights are NERC Priority 6 or NERC Priority 7 firm point-to-point transmission service. No Participant is obligated to offer any such
transmission service rights in the Advance Assessment process, but any
offer so made and not withdrawn before the deadline during the Advance

Assessment process specified in the Business Practice Manuals shall be
considered a binding offer of the identified transmission service rights
which may not be withdrawn before the end of the last Day of the Month for which such transmission service is offered. WPP shall take account of such offered transmission service rights, along with other transmission deliverability reasonably anticipated to be available for use by Participants
for WRAP purposes during the applicable Binding Season in its
determination of the recommended FSPRM values for each Month of the applicable Binding Season for the WRAP Region and for each affected Subregion.
14.4 No later than sixty Days after the FS Deadline for a Binding Season, WPP will (i)
provide the values of the Participant’s FS Capacity Requirement and FS
Transmission Requirement for each Month of the Binding Season; (ii) affirm that the Portfolio QCC of such Participant for each Month of the Binding Season equals or exceeds the FS Capacity Requirement of such Month for such Participant or notify such Participants of any deficiencies in the Forward Showing Submittal that
result in a failure to demonstrate satisfaction of the FS Capacity Requirement; and
(iii) affirm that the Demonstrated FS Transmission plus approved Monthly Transmission Exceptions of such Participant for each Month of the Binding Season equals or exceeds the FS Transmission Requirement of such Month for such Participant or notify such Participants of any deficiencies in the Forward Showing
Submittal that result in a failure to demonstrate satisfaction of the FS Transmission
Requirement.
14.5 Within 120 Days after the FS Deadline, the Participant shall (i) submit revisions to its Forward Showing Submittal, including, without limitation, additions or revisions to the Participant’s Resource QCC, Net Contract QCC, or Demonstrated
FS Transmission; (ii) in order to fully cure all identified deficiencies and
demonstrate that such Participant’s Portfolio QCC for each Month of the Binding Season equals or exceeds its FS Capacity Requirement; and (iii) fully provide Demonstrated FS Transmission for each Month of the Binding Season equals or exceeds its FS Transmission Requirement for the same Month of the Binding
Season where WPP identified deficiencies.
14.5.1 Any Participant that fails to cure identified deficiencies in its Forward Showing Submittal within the period prescribed above shall be assessed an FS Deficiency Charge.

15. Transition Period
15.1 A Participant may elect a Binding Season during the Transition Period as the first
Binding Season for which it will assume the obligations of demonstrating capacity and making surplus capacity available to other Participants and will receive the benefits of reliance upon other Participants’ surplus capacity. As to such Participant, any Binding Season during the Transition Period occurring before the
first Binding Season elected by such Participant shall be a Non-Binding Season.
As to its elected Non-Binding Seasons, the Participant: 15.1.1 Shall not be subject to Capacity Deficiency Charges, Transmission Deficiency Charges, Holdback Requirements, Energy Deployment
obligations, or Delivery Failure Charges;
15.1.2 Shall submit Forward Showing Submittals but shall not be required to cure deficiencies;
15.1.3 Shall not have a mandatory Holdback Requirement as a result of the Sharing
Calculation; 15.1.4 May receive Holdback capacity offered voluntarily by other Participants in accordance with Part III of this Tariff; and

15.1.5 Shall have all rights and be subject to all obligations under Part I of this Tariff and the Participant’s WRAPA, including, without limitation, voting rights, committee participation, and the obligation to pay the WRAP Administration Charge.

15.2 Any Participant that executes a WRAPA prior to January 1, 2023, shall provide any election of Non-Binding Seasons during the Transition Period no later than January 1, 2023. Any Participant that executes a WRAPA on or after January 1, 2023, shall provide any election of Non-Binding Seasons at the time of execution of its
WRAPA. Such elections shall be in writing and in the form and manner provided
in the Business Practice Manuals. A Participant that does not elect Non-Binding Seasons on or before the deadlines prescribed herein shall have no Non-Binding Seasons during the Transition Period.
15.3 No later than two years before the start of the first Binding Season elected by a
Participant, the Participant may give written notification that unanticipated circumstances prevent it from participating in such Binding Season in a manner that will satisfy the requirements of Parts II and III of this Tariff. This deferral right shall continue for each Binding Season during the Transition Period that becomes
the Participant’s first Binding Season as a result of an election of such deferral right
for a prior Binding Season. A Participant that fails to provide such notification will be subject to Parts II and III of this Tariff for the Binding Season then established as its first Binding Season during the Transition Period and for each Binding Season thereafter.

15.4 Within two years prior to the start of the first Binding Season of the WRAP, a
Participant who has elected to participate in the first Binding Season may request a vote of all Participants who have elected to participate in the first Binding Season to delay implementation of the first Binding Season for up to two Seasons. Delayed implementation of the first Binding Season shall be approved if 75% of the
Participants who elected to participate in the first Binding Season vote in favor of
such delay, with approval requiring a vote of 75% of both the House and Senate vote tallies (as described in Sections 4.1.6.2.1 and 4.1.6.2.2 of this Tariff) of all Participants who elected to participate in the first Binding Season.
15.4.1 The deferral vote may only occur for the first Binding Season of the
WRAP. If the Participants who elected to participate in the first Binding Season of the WRAP vote to delay implementation of the first Binding Season, all compliance charges for the Forward Showing Program and Operations Program are automatically deferred; except that the
Participants may vote to delay implementation only of the Operations
Program portion of the first Binding Season and retain the binding Forward Showing Program portion of the first Binding Season.

16. Components of the Forward Showing
16.1 FS Capacity Requirement. The FS Capacity Requirement shall be determined for
each Participant on a monthly basis by applying the applicable Monthly FSPRM
for a Month to such Participant’s peak load forecast for that Month. The
Participant’s peak load forecast for a given Month of a Binding Season will be the
P50 Peak Load Forecast for the Binding Season multiplied by a shaping factor
based on the historic relationship, for such Participant, of the seasonal peak for
the Winter Season or Summer Season, as applicable, and the monthly peaks for
the Months in such season, as more fully described in the Business Practice
Manuals.
16.1.1 P50 Peak Load Forecast. The P50 Peak Load Forecast is a peak load
forecast prepared on a basis, such that the actual peak load is statistically
expected to be as likely to be above the forecast as it is to be below the
forecast. The Business Practice Manuals shall specify an approved load
forecasting methodology for use by all Participants for their WRAP-
required load forecasts which shall include (i) a base monthly peak
derived from a recent historic period that recognizes additions and
removals of load during the historic period, (ii) adjustments for known
additions and removals of load during the forecast window; and (iii) a
specified load growth factor.
16.1.2 FS Planning Reserve Margin
16.1.2.1 The FSPRM is an increment of resource adequacy supply
needed to meet conditions of high demand in excess of the
applicable peak load forecast and other conditions such as
higher resource outages, expressed as a percentage of the
applicable peak load forecast. The FSPRM shall be determined
based on probabilistic analysis, taking account of uncertainties
in generation and load, as the margin above peak load that
provides an expectation of no more than a single event-day of
loss of load in ten years (sometimes referred to herein as the
“1-in-10 LOLE” or 0.1 annual LOLE). The FSPRM shall be
determined in a manner that accounts for the governing
principles of QCC value determinations set forth in Section
16.2.5 of this Tariff and shall employ the applicable peak load
for the applicable Binding Season and Months. Additional
details, assumptions, methodologies, and procedures for
determination of the FSPRM shall be as set forth in the
Business Practice Manuals.
16.1.2.2 WPP shall calculate in the Advance Assessment process the
recommended Monthly FSPRM for each Month of each
Binding Season, for approval by the Board of Directors as set
forth in this Part II.

16.1.2.3 The FSPRM shall employ (i) a simulated resource stack
using capacity accreditation principles consistent with those used
for WRAP QCC determinations; (ii) an adjustment in the total
WRAP-required QCC value as needed to meet a 1-in-10 LOLE,
and (iii) while maintaining the 1-in-10 LOLE in (ii), include a
monthly reduction of capacity to ensure that each Month has at
least 0.01 annual LOLE. The FSPRM for a Month shall be the
simulated QCC as adjusted to meet the 1-in-10 LOLE minus the
P50 Peak Load Forecast for the Month, divided by the P50 Peak
Load Forecast for the Month.
16.1.2.4 The FSPRM shall include an approximation of
Contingency Reserves as set forth in the Business Practice
Manuals.
16.1.3 Contingency Reserves Adjustment. A Participant’s FS Capacity
Requirement will be adjusted as set forth in the Business Practice Manuals
to account for changes in Contingency Reserve requirements resulting
from energy contract purchases and contract sales.
16.1.4 A Participant responsible for loads located in a Subregion for which an
FSPRM value has been determined that is higher than the FSPRM value
determined for a different Subregion may, in lieu of demonstrating a MW
increment of Portfolio QCC otherwise required to satisfy such
Participant’s FS Capacity Requirement for a given Month, demonstrate in
its Forward Showing Submittal, in accordance with the procedures and
requirements set forth in the Business Practice Manuals, transmission
service rights, which such Participant will make available during all hours
of such Month for purposes of regional diversity sharing under the WRAP,
of the type required by the FS Transmission Requirement, in a quantity, in
addition to that required by the FS Transmission Requirement, that is no
greater than the difference in the two FSPRM values multiplied by the
Participant’s P50 Peak Load Forecast, with the point of delivery in the
Subregion with the higher FSPRM value and the point of receipt in the
Subregion with the lower FSPRM value. The MW quantity of the
additional transmission so demonstrated shall reduce for such Month, by
the same MW quantity, the Portfolio QCC the Participant would otherwise
be required to demonstrate to satisfy its FS Capacity Requirement for such
Month. Each such offer shall identify the MW quantity, Month of service,
point of receipt, and point of delivery of such transmission service rights,
and such other information as specified in the Business Practice Manuals,
and shall verify that the offered rights are NERC Priority 6 or NERC
Priority 7 firm point-to-point transmission service. No Participant is
obligated to offer any such transmission service rights, but any offer so
made and not withdrawn before the deadline specified in the Business
Practice Manuals shall be considered a binding offer of the identified

transmission service rights which may not be withdrawn before the end of
the last Day of the Month for which such transmission service is offered.
16.2 Qualified Capacity Contribution
16.2.1 For each Participant and each Binding Season, the Forward Showing shall
show and support the Portfolio QCC, which shall be the sum of the QCC
of the Participant’s Qualifying Resources (“Resource QCC”), the QCC of
its contracted capacity (“Net Contract QCC”), and any transfers of
capacity already accredited by another Participant (“Total RA Transfer,”
which could be positive or negative). The Portfolio QCC effective for a
Binding Season shall be the value determined by WPP.
16.2.2 A resource will not be assigned a Resource QCC or counted toward
Portfolio QCC unless it is a Qualifying Resource. Qualifying Resources
are those that, before they are included in a Forward Showing Submittal,
are first registered with WPP. A Participant seeking registration of a
resource must submit a request for registration providing the resource
information described in the Business Practice Manuals.
16.2.3 The minimum resource size for registration of a resource is 1 MW,
provided, however, that Participants with responsibility for individual
resources of less than 1 MW may aggregate them to meet the 1 MW
minimum requirement, under the conditions and limitations specified in
the Business Practice Manuals.
16.2.4 A Participant may include in its Forward Showing Submittal a request for
an exception from its FS Capacity Requirement for an insufficiency of its
Portfolio QCC solely due to (i) a catastrophic failure of one or more
Qualifying Resources due to an event of Force Majeure as defined by
Section 8.1 of this Tariff that (ii) the Participant is unable to replace on
commercially reasonable terms prior to the FS Deadline as a result of the
timing and magnitude of such catastrophic failure and its consequences.
As more fully set forth in the Business Practice Manuals, such exception
request shall be supported by a Senior Official Attestation. The exception
request must include complete information on the nature, causes and
consequences of the catastrophic failure, and must describe the
Participant’s specific, concrete efforts prior to the FS Deadline to secure
replacement Qualifying Resources for the applicable Binding Season.
WPP will consider the exception criteria established by this section, the
information provided in the exception request, the completeness of the
exception request, and other relevant data and information, in determining
whether to grant or deny an FS Capacity Requirement exception request.
WPP shall provide such determination no later than sixty days after
submission of such Participant’s FS Submittal containing such FS
Capacity Requirement exception request. A Participant granted an
exception hereunder must complete a monthly exception check report

demonstrating that either the circumstances necessitating the exception
have not changed; or that Qualifying Resources have become available,
and the Participant has acquired them and no longer requires the
exception. Failure to timely submit a required monthly report will result
in assessment of a Deficiency Charge, unless the deficiency is cured
within seven days of notice of non-compliance. A Participant denied an
exception request hereunder may appeal such denial to the Board of
Directors in accordance with the procedures and deadlines set forth in the
Business Practice Manuals. In such event, the requested exception shall
be denied or permitted as, when and to the extent permitted by the Board,
in accordance with the procedures and timing set forth in the Business
Practice Manuals. WPP shall give notice of any exception granted
hereunder in the time and manner provided by the Business Practice
Manuals.
16.2.5 QCC: WPP shall determine QCC values for the resource types specified
below in accordance with the governing principles specified below for
each resource type, and consistent with further details specified for each
resource type in the Business Practice Manuals.
16.2.5.1 For resources that use conventional thermal fuels, including but
not limited to, coal, natural gas, nuclear, and biofuel, WPP will
determine QCC based on an Unforced Capacity methodology
that employs resource-specific capability testing and capability
requirements to determine an Installed Capacity value, and a
forced outage calculation methodology based on historic
performance during Capacity Critical Hours over a specified
multi-year period (excluding outages properly reported as
“outside management control”), or based on class-average
forced outage data, as specified in the Business Practice
Manuals, if there is insufficient data on historic performance.
16.2.5.2 For resources that are Variable Energy Resources, including,
but not limited to, wind and solar resources, WPP will
determine QCC based on an ELCC methodology, that accounts
for synergistic portfolio effects within and among VER types at
different resource penetration levels that influence the extent to
which the WRAP Region can rely on those VER categories to
meet overall capacity needs.
16.2.5.2.1 For such purpose, a separate ELCC value will be
calculated in the aggregate for all VER resources of
a given type in an identified VER Zone, to be
delineated in the Business Practice Manuals based
on factors such as geography, performance,
meteorological considerations, and penetration.

16.2.5.2.2 As more fully described in the Business Practice
Manuals, the zonal aggregate VER-resource-type
value will be calculated by (i) conducting a
benchmark LOLE study that includes all resource
types except the VER resource type being studied,
employing a model and assumptions consistent with
those used to calculate FSPRM, and adding, or
subtracting, the same MW quantity of Pure
Capacity to every hour of the applicable Binding
Season until, respectively, an initial LOLE value
above 0.1 day per year becomes 0.1 day per year, or
an initial LOLE value below 0.1 day per year
becomes 0.1 day per year; (ii) conducting an LOLE
study that includes all resource types including the
VER resource type being studied, employing a
model and assumptions consistent with those used
to calculate FSPRM, and adding, or subtracting, the
same MW quantity of Pure Capacity to every hour
of the applicable Binding Season until, respectively,
an initial LOLE value above 0.1 day per year
becomes 0.1 day per year, or an initial LOLE value
below 0.1 day per year becomes 0.1 day per year;
and (iii) subtracting the Pure Capacity value
determined under subpart (ii) from the Pure
Capacity value determined under subpart (i) (for
which calculation a Pure Capacity value subtracted
from each hour in either subpart (i) or subpart (ii)
will be assigned a negative value; (iv) repeating
steps (i) through (iii) for each year of the study
period employing historic, or as necessary,
synthesized, data; and (v) basing the aggregate
value of the studied VER resource type for the
studied VER Zone on the results of the calculation
in step (iii) for the years studied, which may include
differential weighting of the years studied as
appropriate to improve the quality and predictive
capacity of the final result.
16.2.5.2.3 The aggregate capacity calculated for each VER
resource type in each VER Zone will then be
allocated to VERs of that type in that VER Zone
based on each such resource’s average historical
performance if at least three years of historical
performance or three years of synthesized forecast
data during the WRAP Region’s CCH is available
at the time of such allocation. If three years
historical performance or synthesized forecast data

is not then available, the average ELCC from the
VER Zone will be assigned.
16.2.5.3 For resources that are Energy Storage Resources, WPP will
determine QCC based on an ELCC methodology comparable
to that used for VERs. The ELCC methodology will model
Energy Storage Resources at the level of their usable capacity
that can be sustained for a minimum duration of four hours.
An Energy Storage Resource need not have a nameplate rating
that assumes a minimum of four hours in order to receive a
QCC determination, but the QCC in that case will be scaled to
reflect the capability that can be sustained for four hours, as
more fully described in the Business Practice Manuals.
16.2.5.4 For Demand Response capacity resources, WPP will determine
QCC by multiplying the load reduction in MWs by the number
of hours the resource can demonstrate load reduction capability
divided by five. To be a Qualifying Resource, a Demand
Response capacity resource also must satisfy certain testing
requirements; must be controllable and dispatchable by the
Participant or by the host utility; and must not already be used
as a load modifier in the Participant’s load forecast, as further
specified in the Business Practice Manuals.
16.2.5.5 For Storage Hydro Qualifying Resources, the Participant will
calculate a QCC based on a methodology detailed in the
Business Practice Manuals that: (i) considers each resource’s
actual generation output, residual generating capability, water
in storage, reservoir levels, and flow or project constraints over
the previous ten-year historical period; (ii) determines the
project’s QCC by assessing the historical generation during
CCHs on any given day and ability to increase generation
during CCHs on the same day, subject to useable water in
storage, inflows/outflows, and expected project operating
parameters/constraints and limitations; (iii) incorporates forced
outage rates; and (iv) determines QCC as average contribution
to the CCH for each Winter Season and Summer Season over
the previous ten years. If ten years of historic data is not
available for the Storage Hydro Qualifying Resource, the
Participant may alternatively employ data on the same metrics
from a demonstrably comparable facility or apply another
method that provides reasonable confidence in the reliability of
the predicted values, as more fully set forth in the Business
Practice Manuals. The Participant’s QCC calculation shall be
subject to review and validation by WPP. In connection with
such review, the Participant shall provide WPP with the
following information necessary to calculate a QCC for

Storage Hydro Qualifying Resources: (i.a) historic reservoir
elevation levels; (ii.a) historic plant generation; (iii.a) elevation
versus capacity curves; (iv.a) any minimum or maximum
reservoir level constraints; (v.a) forced outage rates; (vi.a)
volume of water versus reservoir elevation storage tables; and
(vii.a) turbine discharge versus generation efficiency curve.
16.2.5.6 For Run of River Qualifying Resources, WPP will determine
QCC based on the monthly average performance of such
resource during Capacity Critical Hours, as further specified in
the Business Practice Manuals
16.2.5.7 For resources that (i) are not within the meaning of any of
Sections 16.2.5.1 through 16.2.5.5, and that (ii) either (a) are
not dispatchable; or (b) require the purchaser of energy from
the resource to take energy as available from such resource,
including but not limited to a qualifying facility as defined
under the Public Utility Regulatory Policies Act of 1978, WPP
will determine QCC based on the monthly average
performance of such resource during Capacity Critical Hours,
as further specified in the Business Practice Manuals.
16.2.6 Net Contract QCC: WPP shall determine Net Contract QCC for the
agreement types specified below in accordance with the governing
principles specified below for each agreement type, and consistent with
further details specified for each agreement type in the Business Practice
Manuals. Net Contract QCC may be either positive or negative, to take
account of, for example, a Participant’s agreements for the sale of capacity
to any other party.
16.2.6.1 Absent one of the exceptions described and limited below,
capacity supply agreements qualifying for a Net Contract QCC
in the WRAP must be resource specific, and therefore must
include, among other requirements, an identified source, an
assurance that the capacity is not used for another entity’s
resource adequacy requirements, an assurance that the seller
will not fail to deliver in order to meet other supply obligations,
and affirmation of NERC priority 6 or 7 firm point-to-point
transmission service rights or network integration transmission
service rights from the identified resource to the point of
delivery/load. The specific resources identified in a capacity
supply agreement qualifying for Net Contract QCC shall meet
the same Resource QCC accreditation requirements for the
given resource type, as specified in Section 16.2.5.
16.2.6.2 A system sales contract can qualify for a Net Contract QCC
value, provided that if the seller is not a Participant, the system

capacity that is the subject of the agreement must be deemed
surplus to the seller’s estimated needs, there must be an
assurance that the seller will not fail to deliver in order to meet
other commercial obligations, and there must be NERC priority
6 or 7 firm point-to-point transmission service rights or
network integration transmission service rights from the
identified resource) to the point of delivery/load. Surplus
status may be demonstrated by a Senior Official Attestation
with pertinent supporting details for such surplus status,
including written assent of the non-Participant Seller, secured
by the purchasing Participant. Such attestation is not required
if the seller is a Participant, because the information needed to
verify surplus status is already available.
16.2.6.3 A supply agreement entered into prior to October 1, 2021
(“Legacy Agreement”) can qualify for a Net Contract QCC
value; provided that where a legacy agreement does not
identify the source, it must be possible for WPP to presume a
source or sources for the contract, including with the written
assent of the supplier under such Legacy Agreement, conveyed
in the form and manner set forth in the Business Practice
Manuals. A Legacy Agreement for which such resource
determination cannot be reasonably made will not be counted
as adding to the Portfolio QCC.
16.2.7 Total RA Transfer: A Participant may agree with another Participant on a
transfer of a portion of their FS Capacity Requirement (“RA Transfer”),
provided that the details and duration of such transfer are reported to WPP
for validation in accordance with procedures and information requirements
specified in the Business Practice Manuals. Where such transfers have
been duly reported and validated, an RA Transfer will be added to the
purchasing Participant’s Portfolio QCC and subtracted from the selling
Participant’s Portfolio QCC.
16.2.8 Planned Outages: Participants shall include in their Forward Showing
Submittal for a Binding Season information on all Qualifying Resources
that are currently out of service with a scheduled return date that falls
during the Binding Season. Capacity associated with such resources must
be deducted from Participants’ Portfolio QCC as specified in the Business
Practice Manuals to ensure no credit is granted for such resources during
the planned outage. The aggregate of any additional outages that are
planned to occur during the Binding Season but have not yet begun at the
time of submission must be within the Participant’s remaining surplus (or
replaced with other supply). Participants may provide information on all
Qualifying Resources that are planned to be out of service but if such data
cannot be supplied with reasonable specificity, a Participant may provide a
Senior Official Attestation at the time of the submission of its FS

Submittal that it expects the sum of planned outages to be equal to or less
than the surplus stated in its FS Submittal throughout the Binding Season.
16.2.8.1 If a Qualifying Resource is planned to return to service within
the first five days of a Binding Season, WPP may approve a
qualified acceptance of the FS Submittal, provided the
deficiency is less than 500 MW.
16.2.8.2 A planned outage shall not justify a waiver of or exception to a
Participant’s holdback or energy delivery obligations under
Part III of this Tariff. Participants will be expected to procure
the necessary capacity or energy to meet the Operations
Program requirements, regardless of planned outage schedules
or FS Submittal acceptance.
16.3 FS Transmission Requirement
16.3.1 As part of its Forward Showing Submittal for a Binding Season, each
Participant must demonstrate, as specified in the Business Practice
Manuals, that it has secured firm transmission service rights, including
under supply arrangements with a third party that holds or has committed
transmission service rights, sufficient to deliver a MW quantity equal to at
least 75% of the MW quantity of its FS Capacity Requirement. To the
extent a Participant holds transmission service rights with a point of
receipt at a Qualifying Resource, or in connection with an RA Transfer to
such Participant, any such rights from such point in a MW quantity,
respectively, in excess of the QCC of such Qualifying Resource, or in
excess of the value of such RA Transfer, shall not contribute toward
satisfaction of such Participant’s FS Transmission Requirement. The FS
Transmission Requirement must be met with NERC Priority 6 or NERC
Priority 7 firm point-to-point transmission service or network integration
transmission service, from such Participant’s Qualifying Resource(s) or
from the delivery points for the resources identified for its Net Contract
QCC or for its RA Transfer to such Participant’s load. Notwithstanding
the foregoing, authorized use of Capacity Benefit Margin will satisfy the
FS Transmission Requirement. Demonstration of the FS Transmission
Requirement shall not, in and of itself, relieve any Participant of
responsibility for a Delivery Failure Charge as determined under Section
20.7 if such Participant’s failure to obtain or maintain firm transmission
service of the type and quantity expected by the Operations Program, as
described in Section 20.6 of this Tariff, caused or contributed to an Energy
Delivery Failure.
16.3.2 A Participant may include in its Forward Showing Submittal a request for
an exception from a limited part of its FS Transmission Requirement,
provided the exception request meets the terms, conditions, and limitations
of one or more of the following four exception categories:

16.3.2.1 Enduring Constraints. Participant is unable to demonstrate
sufficient NERC Priority 6 or NERC Priority 7 firm point-to-point
or network integration transmission service rights on any single
segment of a source to sink path for a Qualifying Resource; and
Participant demonstrates that no ATC for such transmission service
rights is available (either from the transmission service provider or
through a secondary market) at the FS Deadline on the applicable
segment for the Month(s) needed (for a duration of one year or
less) at the applicable Open Access Transmission Tariff rate or
less; and Participant submits a Senior Official Attestation that
Participant has taken commercially reasonable efforts to procure
firm transmission service rights, and that Participant has posted
Firm Transmission Requirements on a relevant bulletin board prior
to the FS Deadline. In the event such transmission service rights
are only available for a duration of more than one year (whether
from the transmission service provider or through a secondary
market) at the FS Deadline on the applicable segment for the
Month(s) needed at the applicable Open Access Transmission
Tariff rate or less, a Participant is not required to obtain such
service in order to qualify for the Enduring Constraints exception
hereunder. Notwithstanding the foregoing, if such Participant
declines to obtain such available service and is granted the
exception hereunder, such Participant shall not qualify for an
exception hereunder for the same path (or across the same
constraint) for the same season of the subsequent year if the
Participant again declines to obtain such transmission service
rights that are available for a duration of more than one year. In
addition to the foregoing, Participant must further demonstrate that
there was remaining available transmission transfer capability (i.e.,
non-firm ATC after the fact) for all CCHs in the same season of
the most recent year for which CCHs have been calculated; or, if
the path was constrained in at least one CCH of the CCHs in the
same season of the most recent year for which CCHs have been
calculated, Participant in that case must demonstrate either that it is
constructing or contracting for a new local resource for at least the
amount of the exception requested, or that it is pursuing long-term
firm transmission service rights by entering the long-term queue
and taking all appropriate steps to obtain at least the amount of the
exception requested.
16.3.2.2 Future Firm ATC Expected. Participant demonstrates that
ATC for NERC Priority 6 or NERC Priority 7 firm point-to-point
or network integration transmission service rights is not posted or
available prior to the FS Deadline (for a duration of one year or
less) at the applicable Open Access Transmission Tariff rate or
less, and that the transmission service provider has, after the FS
Deadline, released additional ATC for such transmission service

rights in every one of the CCHs of the most recent year for which
CCHs have been calculated on the applicable path. In the event
ATC for such transmission service rights is only posted or
available prior to the FS Deadline for a duration of more than one
year (whether from the transmission service provider or through a
secondary market) on the applicable segment for the Month(s)
needed at the applicable Open Access Transmission Tariff rate or
less, a Participant is not required to obtain such service in order to
qualify for the Future Firm ATC Expected exception hereunder.
Notwithstanding the foregoing, if such Participant declines to
obtain such available service and is granted the exception
hereunder, such Participant shall not qualify for an exception
hereunder for the same path (or across the same constraint) for the
same season of the subsequent year if the Participant again
declines to obtain such transmission service rights that are
available for a duration of more than one year. The Participant
must also demonstrate that the exception request meets volume and
duration limitations specified in the Business Practice Manuals.
16.3.2.3 Transmission Outages and Derates. Participant
demonstrates that an applicable segment of its existing
transmission service rights from its source to sink path for its
Qualifying Resource is expected to be derated or out-of-service
and the ATC for NERC Priority 6 or NERC Priority 7 firm point-
to-point or network integration transmission service rights is not
otherwise available, and that the exception request meets volume
and duration limitations specified in the Business Practice
Manuals.
16.3.2.4 Counterflow of a Qualifying Resource. Participant
demonstrates that either: (i) Participant’s use of firm transmission
service in connection with the delivery of capacity from
Participant’s Qualifying Resource (or from the resource associated
with its Net Contract QCC) to Participant’s load (or other
qualifying delivery point permitted by the WRAP) or (ii) a second
Participant’s use of firm transmission service in connection with
the delivery of capacity from the second Participant’s Qualifying
Resource (or from the resource associated with its Net Contract
QCC) to the second Participant’s load (or other qualifying delivery
point permitted by the WRAP) provides a direct and proportional
counterflow transmission that supports the first Participant’s
delivery of capacity from the first Participant’s Qualifying
Resource (or from the resource associated with its Net Contract
QCC) to the first Participant’s load (or other qualifying delivery
point permitted by the WRAP) Qualifying Resource to their load.
If the exception is requested under subpart (ii) of this subsection,
the Participant requesting the exception shall include a written

acknowledgement from the second Participant that it is aware of
such exception request.
As more fully set forth in the Business Practice Manuals, such exceptions
may be subject to overall WRAP limits, and shall be supported by a Senior
Official Attestation. WPP will consider the exception category terms,
conditions and limitations set forth above, and may consider the
completeness of the exception request, information from transmission
service providers, OASIS data, and data readily available to WPP from
other reliable and validated sources concerning the duration, timing,
firmness and quantity of available transmission service or equivalent
options (including transmission construction), in determining whether to
grant or deny a transmission exception request. WPP shall provide such
determination no later than sixty days after submission of such
Participant’s FS Submittal containing such transmission exception request.
A Participant denied an exception request hereunder may appeal such
denial to the Board of Directors in accordance with the procedures and
deadlines set forth in the Business Practice Manuals. In such event, the
requested exception shall be denied or permitted as, when and to the
extent permitted by the Board, in accordance with the procedures and
timing set forth in the Business Practice Manuals. WPP shall give notice
of any exception granted hereunder in the time and manner provided by
the Business Practice Manuals.
A Participant granted a transmission exception under either Section
16.3.2.1 or Section 16.3.2.2 must complete a monthly transmission
exception check report demonstrating that either (i) the circumstances
necessitating the exception have not changed; (ii) transmission has
become available and the Participant has acquired it; or (iii) the Participant
has acquired a different resource, and associated transmission service
rights, and no longer requires the exception. Failure to timely submit a
required monthly report will result in assessment of a Deficiency Charge,
unless the deficiency is cured within seven days of notice of non-
compliance.
16.3.3 To the extent a Participant does not demonstrate satisfaction of its FS
Transmission Requirement by the FS Deadline, the Participant may
correct any such deficiency on or before the end of the cure period
prescribed by Section 14.5 of this Tariff to avoid a Deficiency Charge.
16.3.4. Any deficiency of transmission service rights ultimately determined by
WPP will be treated, for purposes of Deficiency Charge determinations, as
in conjunction with, and not additive to, any deficiencies of QCC
determined pursuant to Section 16.2.

17. Forward Showing Deficiency Charge
17.1 If a Participant fails during the cure period to demonstrate that it has resolved any
identified deficiencies in either or both of its FS Capacity Requirement and its FS Transmission Requirement, the Participant will be assessed a Deficiency Charge for each Month for which a deficiency is identified in accordance with this section. In such case, the deficiency for which the Participant will be assessed a Deficiency
Charge will be calculated in accordance with the following:
Participant’s Monthly Capacity Deficiency = Maximum of (Monthly FS Capacity Requirement – Monthly Portfolio QCC, 0)
Participant’s Monthly Transmission Deficiency (MW) = Maximum of ((75% × Monthly FS Capacity Requirement) – (Monthly Transmission Demonstrated + Approved Monthly Transmission Exemptions), 0)
Where Monthly Transmission Demonstrated is the amount of transmission service rights submitted by a Participant per the requirements in Section 16.3 and validated by WPP for each month.
Monthly Deficiency (MW) = Maximum of (Monthly Capacity Deficiency, Monthly Transmission Deficiency)
17.2 A Participant’s Deficiency Charges shall be calculated as set forth in this Section 17.2, subject to the Transition Period rules in Section 17.3, and shall take account of multiple Monthly Deficiencies within a Forward Showing for a single Binding Season, and multiple Deficiencies across a Forward Showing Year, consisting of a
Summer Season and the immediately succeeding Winter Season, in accordance
with the following:
17.2.1 The Monthly Deficiency with the highest MW value in a Forward Showing for a Summer Season shall be assessed a Deficiency Charge equal to:
Max Summer Deficiency (MW) × Annual CONE ($/kW-year) × 1000 × Summer Season Annual CONE Factor
17.2.2 Any other Monthly Deficiency in the Participant’s Forward Showing for the same Summer Season shall be assessed a Deficiency Charge equal to:
Additional Summer Deficiency (MW) × (Annual CONE ($/kW-year)/12) × 1000 × 200%
17.2.3 Any Monthly Deficiency in the Forward Showing for the immediately
succeeding Winter Season with a higher MW value than the highest MW value of the Monthly Deficiency in the Summer Season shall be assessed a Deficiency Charge on the incremental MW value above the Summer Season equal to:

Maximum of (Max Winter Deficiency – Max Summer Deficiency, 0) (MW) × Annual CONE ($/kW-year) × 1000 × Winter Season Annual
CONE Factor
and in such case where there is a Monthly Deficiency in the Winter Season with a higher MW value than the highest MW value of any Monthly Deficiency in the Summer Season, the Monthly Deficiency with the highest
MW value in the Summer Season shall be assessed an additional Deficiency
Charge calculated in accordance with Section 17.2.2.
17.2.4 Any other Monthly Deficiency in the Participant’s Forward Showing Submittal for the same Winter Season shall be assessed a Deficiency Charge equal to:
Additional Winter Capacity Deficiency × (Annual CONE/12) × 1000 ×
200%
17.2.5 For purposes of the above, CONE is the estimated cost of new entry of a new peaking natural gas-fired generation facility. The CONE estimate shall be based on publicly available information relevant to the estimated annual
capital and fixed operating costs of a hypothetical natural gas-fired peaking
facility. The CONE estimate shall not consider the anticipated net revenue from the sale of capacity, energy, or ancillary services from the hypothetical facility, nor shall it consider variable operating costs necessary for generating energy.
17.2.6 WPP shall review the CONE estimate annually for a possible update. Any
proposed changes in the CONE estimate shall be subject to review through the stakeholder process for program rule changes.
17.2.7 The Summer Season Annual CONE Factor shall vary based on the ratio (“Summer % Deficit”) of the Aggregate Capacity Deficiency for the WRAP
as a whole for that Summer Season, divided by the P50 Peak Load Forecast
for the Summer Season, as follows:
If the Summer % Deficit is less than 1%, the Summer Season Annual
CONE Factor = 125%

If the Summer % Deficit is greater than 1% but less than 2%, the Summer
Season Annual CONE Factor = 150%

If the Summer % Deficit is greater than 2% but less than 3%, the Summer
Season Annual CONE Factor = 175%

If the Summer % Deficit is greater than 3%, the Summer Season Annual
CONE Factor = 200%

17.2.8 The Winter Season Annual CONE Factor shall vary based on the ratio
(“Winter % Deficit”) of the Aggregate Capacity Deficiency for the WRAP
as a whole for that Winter Season, divided by the P50 Peak Load Forecast for the Winter Season, as follows:
If the Winter % Deficit is less than 1%, the Winter Season Annual CONE
Factor = 125%

If the Winter % Deficit is greater than 1% but less than 2%, the Winter
Season Annual CONE Factor = 150%

If the Winter % Deficit is greater than 2% but less than 3%, the Winter
Season Annual CONE Factor = 175%

If the Winter % Deficit is greater than 3%, the Winter Season Annual
CONE Factor = 200%

17.2.9 Notwithstanding Sections 17.2.7 and 17.2.8, if there is either a Summer %
Deficit or a Winter % Deficit in a Forward Showing Year, then for the immediately following Forward Showing Year, both the Summer Season Annual CONE Factor and the Winter Season Annual CONE Factor shall be 200%.
17.2.10. Subject to the Transition Period rules in Section 17.3, revenues from
the payment of Deficiency Charges as to a Binding Season shall be allocated among those Participants with no Deficiency Charges for that Binding Season, pro rata based on each Participant’s share of all such Participants’ Median Monthly P50 Peak Loads for such Binding Season.
17.3 During the Transition Period, Deficiency Charges otherwise calculated under
Section 17.2 shall be reduced as, when, and to the extent, and subject to the conditions, provided in Section 17.3.2; and revenue allocations otherwise calculated under Section 17.2 shall be adjusted as, when, and to the extent, and subject to the conditions, provided in Section 17.3.4.
17.3.1. During the Transition Period, a Participant with a Monthly Capacity
Deficiency can pay a reduced Deficiency Charge for so much of such Monthly Capacity Deficiency as was due to an Excused Transition Deficit. To obtain an Excused Transition Deficit for a Binding Season, the Participant must provide a Senior Official Attestation attesting that the
Participant has made commercially reasonable efforts to secure Qualifying
Resources in the quantity needed to satisfy the Participant’s FS Capacity Requirement for the Binding Season, but is unable to obtain Qualifying Resources in the quantity required for the Binding Season because the supply of such resources on a timely basis and on commercially reasonable
terms is at that time inadequate. Excused Transition Deficits are not

resource specific, relate to a MW quantity of the Participant’s FS Capacity
Requirement, and are limited for each Participant as to a Binding Season
during the Transition Period to a maximum permissible MW quantity equal to a percentage value times the FSPRM applicable to such Participant for all Forward Showing Submittals submitted by such Participant for such Binding Season. For purposes of such calculation, the percentage value is
75% for each of the 2025 Summer Season and 2025-2026 Winter Season,
50% for each of the 2026 Summer Season and 2026-2027 Winter Season, and 25% for each of the 2027 Summer Season and 2027-2028 Winter Season.
17.3.2 A Participant will pay a reduced Deficiency Charge as to the portion of its
Monthly Capacity Deficiency for which it obtained an Excused Transition
Deficit. The Deficiency Charge otherwise applicable to such Participant under Section 17.2 shall be reduced by a percentage value equal to 75% for each of the 2025 Summer Season and 2025-2026 Winter Season, 50% for each of the 2026 Summer Season and 2026-2027 Winter Season, and 25%
for each of the 2027 Summer Season and 2027-2028 Winter Season. The
Participant will be assessed a Deficiency Charge calculated under Section 17.2, without reduction or adjustment, for any of its Monthly Capacity Deficiency that is in excess of the amount of such deficiency for which it obtained an Excused Transition Deficit.
17.3.3 Whether or not a Participant obtains an Excused Transition Deficit as to a
Binding Season, the Participant may reduce a Monthly Capacity Deficiency otherwise calculated under Section 17.1 for a Binding Season during the Transition Period to the extent such deficiency is due to the Participant’s inability to obtain assent from the supplier under a Legacy Agreement to
the accreditation required for such Legacy Agreement under Part II of this
Tariff and the Business Practice Manuals. To obtain such relief, the Participant must provide a Senior Official Attestation attesting that the Participant made commercially reasonable efforts to execute the required accreditation form with the supplier under the Legacy Agreement, but the
supplier was unable or unwilling to counter sign the accreditation form. The
reduction in Monthly Capacity Deficiency permitted by this Section 17.3.3 as to any Participant for all Forward Showing Submittals submitted by such Participant for any Binding Season during the Transition Period shall not exceed a MW quantity equal to 25% times the FSPRM applicable for such
Participant for such Binding Season. To the extent a Participant reduces a
Monthly Capacity Deficiency under this subsection, the percentage of the Participant’s FSPRM corresponding to the reduction hereunder shall reduce the maximum permissible percentage of FSPRM reduction allowed under Section 17.3.1 for Excused Transition Deficits for the same Binding Season.
17.3.4 A Participant that, as a result of application of this Section 17.3, pays no
Deficiency Charge as to a Binding Season, shall not be deemed a “Participant[ ] with no Deficiency Charges” for purposes of Section

17.2.10, and shall not receive an allocation of revenues from the payment
of Deficiency Charges as to such Binding Season.

PART III OPERATIONS PROGRAM

18. Operations Program Overview
18.1 The Operations Program facilitates access to collective capacity made available
through regional load and resource diversity of all Participants under the terms of this Part III.
18.2 The Operations Program evaluates forecasted system conditions across the seven-day period (“Multi-Day-Ahead Assessment”) preceding the Operating Day,
commencing at the outset of the assessment period with an initial Sharing
Calculation and initial identification of potential Sharing Events for the Operating Day. The assessment is refined as forecasted conditions for the Operating Day are revised and established on the Preschedule Day, a Holdback Requirement for any Sharing Events is then identified. To the extent a Sharing Event continues to be
identified for the Operating Day, Holdback Requirements shall be converted into
Energy Deployments on the Operating Day.
18.3 The Operations Program prescribes pricing designed to incent Participants to resolve any forecast Operating Day deficiencies before the Operating Day, including through transactions outside the Operations Program, and to fully
compensate Participants that provide support through the Operations Program to
Participants with Operating Day deficiencies.

19. Operations Program Timeline and Supporting Information
19.1 The Multi-Day Ahead Assessment is conducted for the seven rolling days before
each Operating Day. WPP shall prepare and post a forecast for the Operating Day on the first day of the Multi-Day-Ahead Assessment, revise the forecast each day thereafter, including on the Preschedule Day, and then revise the forecast hourly into the Operating Day during any Sharing Event.
19.2 The Operations Program, during any Binding Season, shall rely on and employ
(among other data) the following information from the Forward Showings for such Binding Season: (i) the P50 Peak Load Forecast for each Participant; (ii) the Monthly FSPRMs for each Participant during such Binding Season; (iii) expected performance by Qualifying Resource type and any RA Transfers; (iv) expected
forced outage rates by resource type; (v) expected Contingency Reserves; and (vi)
firm transmission service rights made available for purposes of regional diversity sharing under the WRAP, as demonstrated by Participants in their Forward Showing Submittals, as permitted under Part II of this Tariff, which shall be assumed to be available for all hours of each Month for which such firm
transmission service rights were made available.
19.3 To facilitate WPP’s conduct of the Multi-Day-Ahead Assessment, each Participant shall provide the Program Operator information relevant to the Participant’s expected demand and supply conditions on each Operating Day, of the type, in the manner, and with the frequency, specified in the Business Practice Manuals.
19.4 Each Participant in any Subregion identified in the Business Practice Manuals as
not containing a central transmission hub permitting energy deliveries to that hub from any point within such Subregion, shall, in addition to providing the information required by Section 19.3, identify, on or before the deadline during the Preschedule Day specified in the Business Practice Manuals, for each Hour of the
Operating Day each point to which it can deliver energy, each point at which it can
take receipt of energy, the quantity it can deliver or receive at each such point, and a numeric factor intended to prioritize use of transmission made available by Participants with positive Sharing Calculations and needed by Participants with negative Sharing Calculations for each such hour, employing for such purpose the
numeric factor developed by WPP with input from the stakeholder committees
identified for such input in the Business Practice Manuals. A Participant with a positive Sharing Calculation for an hour must provide a total quantity for all identified points at which it can deliver that is no less than the amount of its positive Sharing Calculation for such hour (adjusted as necessary for any RA Transfer in
accordance with Section 20.1.2). A Participant with a negative Sharing Calculation
for an hour must provide a total quantity for all identified points at which it can take receipt that is no less than the amount of its negative Sharing Calculation for such hour (adjusted as necessary for any RA Transfer in accordance with Section 20.1.2). Participants shall provide this same information for each Operating Day on an
expected or preliminary basis on each day of the Multi-Day-Ahead Assessment

following, and based on, the expected Holdback Requirement estimates provided
on each such day for the Operating Day.
19.5 Any Participant may, at its sole election, in addition to the information and priorities provided pursuant to Section 18.4, offer on the Preschedule Day additional holdback capacity, or additional transmission service rights, including intermediate
or wheeling transmission service, for use by other Participants under Part III of this
Tariff. Any such offer shall include for such offered holdback or transmission service rights the same type of point of receipt, point of delivery, quantity, and numeric factor information required by Section 19.4 as well as any associated or resulting limit on such Participant’s offered holdback.

20. Components of the Operations Program
20.1 Sharing Requirement
20.1.1 WPP shall implement, as more fully described in the Business Practice Manuals, with respect to each Forward Showing Submittal accepted by WPP for a Participant under Part II of this Tariff, or with respect to each Subregion in which the Participant is responsible for load regardless of
whether the Participant submitted a single Forward Showing Submittal
encompassing its loads in both Subregions, the following Sharing Calculation to identify any hour in which any Participant is forecast to have a capacity deficit (known as a “Sharing Event”). This calculation takes into account changes in a Participant’s resource availability, resource
performance, forecast load, and Contingency Reserves relative to the
Forward Showing, plus an Uncertainty Factor. The Sharing Requirement is equal to: [P50 + FSPRM – Regional Diversity Transmission -- ΔForced Outages
+ ΔRoR Performance + ΔVER Performance] – [Load Forecast + ΔCR
+ Uncertainty Factor] Where:
P50 refers to the Participant’s Monthly P50 Peak Load for that Binding
Season’s month; FSPRM refers to the MW quantity of the FSPRM percentage applied to the Participant P50 Peak Load Forecast for that Participant for that Binding
Season;
Regional Diversity Transmission refers to the MW quantity of additional transmission service rights made available for purposes of regional diversity sharing under the WRAP, as demonstrated by the Participant in its Forward
Showing Submittal in lieu of demonstrating an equal MW quantity of
Portfolio QCC, as permitted under Part II of this Tariff; provided that when separate Sharing Calculations are performed for each of two Subregions in which a Participant is responsible for load, the Regional Diversity Transmission shall be equal to the lower of (i) the additional firm
transmission service rights (above that required for the FS Transmission
Requirement) demonstrated in the Participant’s Forward Showing Submittal and (ii) the additional firm transmission service rights (above that required for the FS Transmission Requirement) demonstrated in the Participant’s Forward Showing Submittal minus any transfer made from the
Subregion with the lower PRM to the Subregion with the higher FS PRM
to address all or part of a negative Sharing Calculation result in the Subregion with the higher FSPRM.

𝜟𝜟 𝑭𝑭𝑭𝑭𝑭𝑭𝑭𝑭𝑭𝑭𝑭𝑭 𝑶𝑶𝑶𝑶𝑶𝑶𝑶𝑶𝑶𝑶𝑭𝑭𝑶𝑶 refers, for the subject hour, to: (i) any change in forced outages of any of the thermal resources included in the Participant’s
Portfolio QCC, relative to the forced outages assumed in the Forward
Showing Submittal by application of the Forced Outage Factor; (ii) any change in forced outages of any of the Storage Hydro Qualifying Resources relative to the forced outages assumed in the calculation of the Participant’s Resource QCC as more fully described in the Business Practice Manuals;
and (iii) any impacts of transmission conditions on previously acquired firm
transmission service rights that result in capacity reductions up to the level of the Resource QCC of the associated Qualifying Resource; 𝜟𝜟𝜟𝜟𝑭𝑭𝜟𝜟 𝑷𝑷𝑭𝑭𝑭𝑭𝑷𝑷𝑭𝑭𝑭𝑭𝑷𝑷𝑶𝑶𝑷𝑷𝑭𝑭𝑭𝑭 refers to any change, for the subject hour, in expected performance of any of the run-of-river resources in the
Participant’s Portfolio QCC relative to the QCC of that Qualifying
Resource; 𝜟𝜟𝜟𝜟𝜟𝜟𝜟𝜟 𝑷𝑷𝑭𝑭𝑭𝑭𝑷𝑷𝑭𝑭𝑭𝑭𝑷𝑷𝑶𝑶𝑷𝑷𝑭𝑭𝑭𝑭 refers to any change, for the subject hour, in expected performance of the VER Resources in the Participant’s Portfolio QCC relative to the QCC of that Qualifying Resource;
Load Forecast refers to the forecast of expected load for the subject hour
for the loads for which the Participant is responsible; 𝜟𝜟𝜟𝜟𝜟𝜟 refers to any change in Contingency Reserves for the subject hour, relative to that assumed in the Participant’s Forward Showing Submittal; and
Uncertainty Factor refers to a factor determined by WPP, as more fully set forth in the Business Practice Manuals, to account for the potential variance between forecasts of load, solar resources, wind resources, and run-of-river resources, and the Operating Day conditions of such load and resources
based on historic data.
20.1.2 In addition to the foregoing, the Sharing Calculation for a Participant that is a purchaser of an RA Transfer shall be performed in two passes, with and without such purchase. If the result of assuming in the first pass that the Participant had not purchased the RA Transfer is that the Participant has a
negative Sharing Calculation, then the Participant that sold the RA Transfer
must agree, for the time period addressed by the Sharing Calculation, to an energy delivery to the Participant that purchased the RA Transfer, in an amount equal to the lesser of: (i) the MW quantity needed to result in a net zero Sharing Calculation for the Participant that purchased the RA Transfer;
and (ii) the MW amount of the RA Transfer. If the result of recognizing the
Participant’s purchase of the RA Transfer in the second pass is that the Participant has a positive Sharing Calculation, then the Participant that sold the RA Transfer must assume a share of the purchasing Participant’s resulting obligation to the Operations Program in an amount equal to the

MW quantity of the RA Transfer, minus the MW quantity of the delivery
made by the seller of the RA Transfer to the purchaser of the RA Transfer
as a result of the first pass.
20.1.3 The Sharing Calculation of any Participant that was found to have a Monthly Capacity Deficiency under Sections 16.1 and 16.2, for which such Participant paid an FS Deficiency Charge, including any Deficiency Charge
reduced by application of Section 17.3 during the Transition Period, shall
be reduced by the MW quantity of such Monthly Deficiency. During the Transition Period, a Participant that had a Deficiency Charge as to a Binding Season reduced by application of Section 17.3 shall receive a lesser priority to Holdback and Energy Deployments during such Binding Season relative
to Participants that, as to the same Binding Season, had no Monthly
Capacity Deficiency under Sections 16.1 and 16.2, or had a Monthly Capacity Deficiency under those sections but obtained no reduction in the Deficiency Charge under Section 17.3. Such priority shall apply only in the event that during a Sharing Event, there is insufficient Holdback available
to satisfy the deficits of all Participants with a negative Sharing Calculation,
or in the event that there is insufficient Energy Deployment available to satisfy the deficit positions of all Participants that confirmed a need for Energy Deployment. In either such event, the Holdback, or Energy Deployment, available to Participants that had their Deficiency Charges
reduced by Section 17.3 shall be limited to that available after satisfying the
deficit positions of Participants that did not had no Monthly Capacity Deficiency under Sections 16.1 and 16.2, or had a Monthly Capacity Deficiency under those sections but obtained no reduction in their Deficiency Charge under Section 17.3.
20.2 Holdback Requirement
20.2.1 To the extent that: (i) WPP’s application of the Sharing Calculation identifies on the Pre-Schedule Day a Sharing Event for any hour(s) of the Operating Day; and (ii) the Participant(s) found to be deficient for such hour(s) by the Sharing Calculation confirms to the WPP, in accordance with
notification and confirmation procedures set forth in the Business Practice
Manuals, such Participant’s need for capacity for such hour(s), then WPP shall determine the Participants having a Holdback Requirement for such hour(s) and the quantity of the Holdback Requirement for each such Participant in accordance with the following Holdback Calculation:
Participant Holdback Requirement = Participant Sharing Ratio ×
Total Program Sharing Requirement where:

Participant Sharing Ratio = [the positive Sharing Requirement, if any,
calculated for such Participant] / Σ positive Sharing Requirements of all
Participants having a positive Sharing Requirement for such hour] Total Program Sharing Requirement = abs( Σ negative Sharing Requirements of all Participants having a negative Sharing Requirement for
such hour)
Holdback Requirements shall be expressed as whole MWs for each hour for which they are estimated or established and shall not be specific to any Qualifying Resource.
20.2.2 Absent a Holdback Requirement Transfer as described below, a
Participant’s Holdback Requirement for any hour of an Operating Day shall not exceed the level first set by WPP on the Preschedule Day for that Participant for that hour. Prior to establishing the Holdback Requirement for an hour of an Operating Day, WPP, during the Multi-Day-Ahead
Assessment, will estimate, and provide to affected Participants, an expected
Holdback Requirement for such hour of the Operating Day. As expected, conditions change over the Multi-Day-Ahead Assessment, WPP may adjust its estimate of the expected Holdback Requirement for such hour, applying the same considerations and principles set forth in Section 20.3.1 for a
release of a Holdback Requirement, as well as the same process and
considerations for early release of Holdback Requirement set forth in Section 20.3.1.1. When WPP notifies affected Participants of such reduction, the Holdback Requirement established on the Preschedule Day shall not exceed the reduced level previously estimated by WPP for such
hour.
20.2.3 Any Participant may agree with any other Participant for the first Participant to transfer to the second Participant some or all of the Holdback Requirement established for the first Participant for any hour on any Operating Day. Any such Holdback Requirement Transfer shall be a
bilateral arrangement settled outside the Operations Program, provided,
however, that both Participants must timely notify WPP, by the time and in the manner described in the Business Practice Manuals, of such Holdback Requirement Transfer. Any necessary transmission arrangements and any transaction settlements shall be the sole responsibility of the Participants
that are the parties to such bilateral arrangement.
20.3 Release of Holdback Requirement
20.3.1 As detailed in the Business Practice Manuals, WPP will review Holdback Requirements for each hour of an Operating Day following the establishment during the Preschedule Day of any Holdback Requirement
for that hour. To the extent the WPP determines any Holdback
Requirements can be reduced, it shall release all or a portion of Participants’

Holdback Requirements. WPP will permit a release of Holdback
Requirements to the extent WPP has not applied a Safety Margin for such
hour and (i) WPP’s continued Sharing Calculations determine that no Participant has a negative Sharing Requirement for such hour; and (ii) WPP determines there is a low probability of a Sharing Event for the hour; or (iii) WPP grants a Participant’s request for extenuating circumstances of all or
any portion of that Participant’s Holdback Requirement for the hour.
20.3.1.1 In advance of the process described in Section 20.3.1 WPP may, on its own or in response to a Participant request, set a ceiling on the Holdback Requirement based on application of the same considerations set forth in Section 20.3.1 for a release of a Holdback
Requirement.
20.3.2 Upon release of all or any portion of a Holdback Requirement, the quantity of Holdback Requirement so released shall no longer be subject to an Energy Deployment requirement under the Operations Program for the subject hour.
20.3.3 No Holdback Requirement transfer for any hour shall be permitted if notice
of such bilateral transaction is not fully reported to WPP, in the form required by the Business Practice Manuals, by 120 minutes before the start of such hour.
20.4 Energy Deployment
20.4.1 Participants shall provide energy during an hour, in support of any
Participants with a negative Sharing Requirement and a confirmed need for energy under the Operations Program for such hour, in accordance with WPP’s calculation of the Energy Deployment for such hour.
20.4.1.1 For any hour, as to any Subregion identified in the Business
Practice Manuals as containing a central transmission hub
permitting energy deliveries to that hub from any point within such Subregion, the total Energy Deployment required of all Participants that are subject to Energy Deployment shall equal the sum, in MWh for that hour, of the energy confirmed as being needed in that hour
by Participants in such Subregion with negative Sharing
Requirements in such hour, to the extent that can be supported by the Program. The Energy Deployment required from a Participant in such Subregion in such hour shall be that Participant’s pro rata share of the total Energy Deployment for such Subregion, based on
the ratio of that Participant’s final Holdback Requirements for such
hour to the sum of all final Holdback Requirements for that hour. Energy Deployments required hereunder shall be delivered to the central transmission hub in such Subregion, or to an alternate delivery point mutually agreed by the parties to a specific Energy

Deployment, provided both parties to the transaction report such
alternative delivery arrangements to WPP in the form and manner
described in the Business Practice Manuals.
20.4.1.2 For any hour, as to any Subregion identified in the Business Practice Manuals as not containing a central transmission hub permitting energy deliveries to that hub from any point within such
Subregion, WPP shall conduct an optimization calculation that
prioritizes use of transmission service voluntarily offered by a Participant pursuant to Section 19.3.1 and additional holdback capacity and transmission service voluntarily offered pursuant to Section 19.5, and that employs the receipt point and delivery point
information, quantities, and numeric factors provided pursuant to
Section 18.4 as well as any associated or resulting limit on such Participant’s offered holdback, to match and allocate provision of Energy Deployment and receipt of Energy Deployment within the following categories: (i) holdback and transmission service rights
offered pursuant to Section 19.5; (ii) transmission service offered
pursuant to Section 19.3.1, paired with any holdback offered pursuant to Section 19.5 that is not fully used by category (i); (iii) Holdback Requirement under Section 20.2 matched pursuant to the information provided pursuant to Section 19.4 on a nearest neighbor
cluster basis, allocated pro rata among Participants within such
cluster; (iv) Holdback Requirement under Section 20.2 matched pursuant to the information provided pursuant to Section 19.4 and allocated among Participants within the same Subregion to the extent not matched and allocated under category (iii); and (v)
Holdback Requirement under Section 20.2 from Participants in
another Subregion, paired with any transmission service offered pursuant to Section 19.3.1 that is not fully used by category (ii). 20.4.2 The Energy Deployment a Participant may receive for any hour shall be no
greater than the negative Sharing Requirement calculated for such
Participant for such hour. Such Participant shall confirm, by no later than 120 minutes before the start of such hour, the quantity of Energy Deployment for which it requires delivery for such hour, through the procedures outlined in the Business Practice Manuals. Any Participant that
does not confirm required Energy Deployment deliveries for such hour by
such deadline will be deemed to waive all deliveries of Energy Deployment under the Operations Program for such hour. See Section 21.2 Settlement Price Calculation below for payment obligations.
20.4.3 The Energy Deployment a Participant can be required to supply for an hour
shall not exceed the final Holdback Requirement calculated for such
Participant on Pre-Schedule Day, including any duly reported exchange of Holdback Requirement, as of 120 minutes before the start of such hour. Any Participant for which WPP calculated during the Preschedule Day a

negative Sharing Requirement for the hour in question shall have zero
Holdback Requirement and shall not have any Energy Deployment
obligation for that hour.
20.4.4 WPP shall advise each Participant with a required Energy Deployment for an hour of the required MWh quantity and delivery point of such Energy Deployment by no later than ninety minutes before the start of such hour.
20.4.5 Participants may engage in voluntary, bilateral transfers of Energy
Deployment obligations for an hour, provided that the Participants assume sole responsibility for any required transmission arrangements and settlement of such bilateral transfer. All such bilateral transfers must be reported to WPP no later than the third Business Day of the Month
following the Month in which the transfer occurs.
20.5 Safety Margin
20.5.1 WPP may establish on the Preschedule Day a Safety Margin for the WRAP Region or any identified Subregion thereof for any hour of an Operating Day when warranted by such circumstances as potential large resource trips,
heavy transmission outage conditions, significant environmental
conditions, or other similar regional or subregional conditions, as more fully set forth in the Business Practice Manuals.
20.5.2 Any Safety Margin so determined for an hour shall be allocated pro rata among Participants with a positive Sharing Requirement, based on their
relative shares of the sum of all positive Sharing Requirements for such
hour, provided, however, that the Safety Margin allocated to a Participant may not result in a Holdback Requirement for such Participant greater than such Participant’s Sharing Requirement. A Participant allocated holdback for a Safety Margin hereunder does not receive compensation under this
Tariff for such allocation of holdback.
20.5.3 WPP shall notify all Participants of application of a Safety Margin for any hour, including in such notice the total timeframe, the MW amount, and the rationale for such Safety Margin.
20.6 Operations Program Transmission Service Requirements
Participant shall have in place, prior to the Operating Day, transmission service
satisfying NERC priority 6 or 7 for each hour of such Operating Day for which a Sharing Event has been established, in a quantity sufficient for deliveries from the Qualifying Resources relied upon in such Participant’s Forward Showing Submittal to demonstrate satisfaction of such Participant’s FS Capacity Requirement (or from
replacement Qualifying Resources) to serve such Participant’s loads during such
hours. In the event a Participant has an Energy Delivery Failure, the review associated with the possible assessment of a Delivery Failure Charge on such Participant shall, as further described in the Business Practice Manuals, include

whether a failure to secure sufficient NERC priority 6 or priority 7 firm
transmission service rights caused or contributed to such Energy Delivery Failure.
For such purpose, the Participant will have been expected to have complied with the transmission service requirement stated in this subsection.
20.7 Failure to Deliver Energy Deployments
20.7.1 A Participant assigned a required Energy Deployment pursuant to Section
20.4.4 of this Tariff for any hour that fails to deliver the specified energy
during such hour, and that does not obtain a waiver of its Energy Deployment obligation, shall be assessed a Delivery Failure Charge.
20.7.2 A Participant shall be deemed to have an Energy Delivery Failure if Participant fails to deliver the Energy Deployment quantity established
under Section 20.4.1, absent grant of a waiver pursuant to Section 20.7.3 of
this Tariff.
20.7.3 A Participant anticipating an Energy Delivery Failure should provide WPP notice of such expected Energy Delivery Failure as soon as practicable after becoming aware of the anticipated failure. Whether anticipated or not, a
Participant may request a waiver of an Energy Deployment obligation after
an Energy Delivery Failure has occurred. The WPP shall review all such waiver requests and shall determine whether the Participant’s justification for the Energy Delivery Failure is valid and warrants waiver of its Energy Deployment obligation. The WPP also shall consider whether the
Participant knew in advance, or reasonably should have known in advance,
of an Energy Delivery Failure, and what efforts the Participant took to notify the WPP in advance of such Energy Delivery Failure. The procedures for addressing such waiver requests, including a non-exclusive list of valid justifications for an Energy Delivery Failure shall be set forth in the
Business Practice Manuals. A Participant denied a waiver request
hereunder may appeal such denial to the Board of Directors in accordance with the procedures and deadlines set forth in the Business Practice Manuals. In such event, the requested waiver shall be denied or permitted as, when and to the extent permitted by the Board, in accordance with the
procedures and timing set forth in the Business Practice Manuals. WPP
shall report on the disposition of each waiver request received.
20.7.4 The Delivery Failure Charge for each hour shall be the Charge Rate applicable for such hour times the MWhs of energy that were required to be, but were not, delivered pursuant to an Energy Deployment during such
hour. The Charge Rate shall be the higher of the Day-Ahead price or Real-
Time price provided by the Day-Ahead Applicable Price Index and Real-Time Applicable Price Index as specified in the Business Practice Manuals for the Subregion applicable to the location of the delivering entity, applicable to the day and hour of the energy delivery, respectively, for the
hour, times a Delivery Failure Factor, as follows:

20.7.4.1 If the deficit is fully covered by other Participants through
the Operations Program, in each instance of failure, the Delivery
Failure Factor shall be five for the first non-waived Energy Delivery Failure in a Cumulative Delivery Failure Period; ten times for the second non-waived Energy Delivery Failure in a Cumulative Delivery Failure Period; and twenty times for the third and
subsequent non-waived Energy Delivery Failures in a Cumulative
Delivery Failure Period. For purposes of applying the Delivery Failure Factors under this Section 20.7.4 or the review referenced in Section 20.7.5, multiple Energy Delivery Failures occurring in one day shall be treated as a single instance of failure.
20.7.4.2 If the deficit is not fully covered by other Participants
through the Operations Program, the Delivery Failure Factor is twenty-five times for the first non-waived Energy Delivery Failure in a Cumulative Delivery Failure Period; and fifty times for the second and subsequent non-waived Energy Delivery Failures
(regardless of whether the prior instance(s) of delivery failure were
fully covered by other Participants) in a Cumulative Delivery Failure Period.
20.7.4.3 Revenues from Delivery Failure Charges assessed in cases where the deficit was fully satisfied by other Participants will be
used to reduce WPP costs that are recovered under Schedule 1,
WRAP Administration Charge. Revenues from Delivery Failure Charges assessed in cases where the deficit was not fully met by other Participants will be collected by the WPP and provided to the Participant that had an unserved deficit.
20.7.4.4 Notwithstanding anything to the contrary in this Section
20.7.4, the Delivery Failure Charges assessed on a Participant, regardless of application of the Delivery Failure Factor, shall not exceed, over the course of a Summer Season and the immediately succeeding Winter Season, the dollar amount that, as more fully
detailed in the Business Practice Manuals, would have been assessed
cumulatively under Section 17 as Deficiency Charges if the Participant had one or more Forward Showing Capacity Deficiencies over the course of such Summer Season and Winter Season in the same MW amounts as the highest MW amount of
Delivery Failure experienced by such Participant in each Month of
such Summer Season and Winter Season. The maximum dollar amount described herein shall be calculated on an ongoing basis during such Summer Season and Winter Season, and increased or reduced accordingly, without awaiting the end of the combined
period of such Summer Season and Winter Season.

20.7.5 In addition to assessment of the Delivery Failure Charge, a third or
subsequent instance of non-waived delivery failure, when all such delivery
failures are fully covered by other Participants, or a second or subsequent instance of non-waived delivery failure when such instance is not fully covered by other Participants, will subject the Participant to review for expulsion from the WRAP.
20.8 Voluntary Response to Increased Deficiencies Identified After Pre-Schedule Day
20.8.1 A Participant that identifies an unmet need for energy for any hour of an Operating Day that is in excess of assistance provided or to be provided by Holdback Requirements or Energy Deployments established hereunder may, in accordance with procedures specified in the Business Practice
Manuals, notify WPP of the need for such assistance. WPP will establish a
portal or other procedure, as specified in the Business Practice Manuals, to facilitate provision of assistance, on a voluntary, bilateral basis, by other Participants to the Participant that identified the unmet need. Compensation, terms, and conditions of any resulting bilateral transactions
will be determined by the affected parties outside of this Tariff. While
Participant response to any such notification is voluntary, Participants are encouraged to provide assistance to other Participants in the circumstances described in this subsection, in consideration of the mutual support each Participant has agreed to provide to each other Participant by its agreement
to participate in the WRAP, including this Operations Program. Voluntary
provision of assistance by one Participant to another Participant hereunder shall follow priority tiers during the Transition Period based on the status or condition of the Participant seeking assistance, with the first priority afforded to Participants during a Binding Season (as to such Participant)
that had no Monthly Capacity Deficiency for the applicable Month, or that
paid a Deficiency Charge that was not reduced under the Transition Period provisions of Part II of this Tariff; the second priority afforded to Participants during a Binding Season (as to such Participant) that obtained relief from a Monthly Capacity Deficiency and Deficiency Charges for the
applicable Month under the Transition Period provisions of Part II of this
Tariff; and the third priority afforded to Participants during a Non-Binding Season (as to such Participant).

21. Operations Program Settlements
21.1 Nature of Operation Program Settlements
21.1.1 Operations Program settlements are bilateral transactions; they are not purchases from or sales to a central market.
21.1.2 Operations Program transactions use existing transaction systems and processes.
21.1.3 The WPP will calculate and post settlement quantities and prices based on
the Energy Deployment and Holdback Requirement, in accordance with procedures specified in the Business Practice Manuals for provision of transaction information by and among Participants and WPP, but WPP has no role in the transaction itself. WPP is not a settlement entity.
21.1.4 Settlement Prices calculated under Section 21.2 shall recognize pricing
differences among Subregions. Where the seller and buyer are located in the same Subregion, the Applicable Price Index shall be the price index specified for that Subregion in the Business Practice Manuals. Where the seller and buyer are located in different Subregions, the following
components of the settlement price calculation in Section 21.2 will be
calculated using the Applicable Price Index for the Subregion that provides the higher index price: (i) Possible Block Sale Revenue; (ii) Total Settlement Price; (iii) Energy Declined Settlement Price; and (iv) Realtime Value of Unheld Energy. If a third participant is involved by providing
transmission service rights between Subregions, the Participant that
provided holdback or Energy Deployment shall receive the settlement price of the Subregion from which the holdback or Energy Deployment was sourced, and the Participant that provided Subregion to Subregion transmission service rights pursuant to Section 19.3.1 shall receive the
difference between each Subregion’s Total Settlement Price, or zero,
whichever is greater.
21.2 Settlement Price Calculation. Settlement prices shall be calculated in accordance with the following, as more fully set forth in the Business Practice Manuals.
21.2.1 A Participant assigned a Holdback Requirement on a Preschedule Day for
any hour of an Operating Day shall be paid the Holdback Settlement Price
times the MW quantity of the Holdback Requirement. A Participant that provides energy to another Participant pursuant to an Energy Deployment shall be paid the Energy Declined Settlement Price, defined in Section 21.2.4, times the MWhs of energy provided to such other Participant, and
its total payments shall be reduced by the Energy Declined Settlement Price
times the MWhs of energy that would have been provided under a Holdback Requirement but were declined by the other Participant. A Participant

assigned a Holdback Requirement also shall be paid, when applicable, a
Make Whole Adjustment, as provided below in Section 21.2.5.
21.2.2 A Participant that had a negative Sharing Requirement for any hour of an Operating Day, which was incorporated in the calculation of Holdback Requirements of any Participants for such hour, determined as of the Preschedule Day, shall pay the Holdback Settlement Price times the MW
quantity of such negative Sharing Requirement. In addition, any Participant
that had a negative Sharing Requirement that was incorporated in the calculation of a Holdback Requirement shall contribute to the payment of the Make Whole Adjustment based on its negative Sharing Calculation. A Participant that declines energy that would have been provided under a
Holdback Requirement shall be credited the Energy Declined Settlement
Price times the MWhs of energy declined by such Participant.
21.2.3 The Holdback Settlement Price shall equal the Total Settlement Price minus the Energy Declined Settlement Price.
21.2.4 The Energy Declined Settlement Price shall equal the lesser of (i) 0.80 times
the Total Settlement Price, or (ii) the Applicable Real-Time Index Price for
the hour.
21.2.5 The Make Whole Adjustment is applied in the event that the settlement revenue and the estimated value of the non-dispatched energy is less than the estimated revenues the selling entity would have received had such
entity not been subject to a Holdback Requirement and had sold a day-ahead
block of energy with a MW value equal to the maximum amount of Holdback Requirement for the hours in the block, and is determined as follows:
Make Whole Adjustment (when applicable) = Possible Block Sale Revenue
− Final Settlement Revenue
− Realtime Value of Declined Energy
− Realtime Value of Unheld Energy
Where:
Realtime Value of Declined Energy = Energy Declined × Energy Declined Settlement price
provided that Declined Energy is only applicable to those hours where
there was a positive Holdback Requirement.
Realtime Value of Unheld Energy = (Maximum Holdback MW in Block – Holdback MW Requested) × Applicable Index Price

21.2.6 The Total Settlement Price used in the above calculations shall be
determined in accordance with the following formula:
Total Settlement Price = Maximum of (Minimum of (Hourly Shaping Factor × Day Ahead Applicable Index Price × 110%, 2000 $/MWh), 0)
where:
Hourly Shaping Factor is based on the most recent High-Priced Day for
the relevant season, defined as a day in which at least one hour has a system marginal energy cost (“SMEC”) greater than $200/MWh, and shall be calculated as follows:
1 + {[CAISO Hourly Day Ahead SMEC - CAISO Average Day Ahead
SMEC (on- or off-peak hours)] / [CAISO Average Day Ahead SMEC (on- or off-peak hours)]} Day-Ahead Applicable Index Price is the day-ahead heavy load/light load
ICE Index price that is specified in the Business Practice Manuals for the
Subregion applicable to the location of the delivering entity, applicable to the day and hour of the energy delivery. If donated transmission was used to facilitate holdback, the Applicable Index Price shall be the higher of the two subregional day-ahead index prices for that portion of the holdback.

Real-Time Applicable Index Price is the real-time index price that is specified in the Business Practice Manuals for the Subregion applicable to the location of the delivering entity, applicable to the day and hour of the
energy delivery.

SCHEDULE 1
WESTERN RESOURCE ADEQUACY PROGRAM ADMINISTATIVE COST RECOVERY CHARGE
The Western Power Pool’s Costs of administering and operating the Western Resource Adequacy
Program including, without limitation, all costs incurred or obligated by WPP as Program Administrator, all costs paid or payable by WPP to the Program Operator or other service providers, all costs of the Board of Directors in directing, supervising, or overseeing the WRAP, and the costs of maintaining a reasonable reserve as provided in Section 1 of this Schedule 1, shall
be recovered from Participants pursuant to the charges set forth in this Schedule 1.
Section 1. WRAP Costs 1. As used herein, Costs shall mean WPP’s costs, expenses, disbursements and other
amounts incurred (whether paid or accrued) or obligated of administering and
operating the WRAP as described above, including, without limitation, operating expenses, general and administrative expenses, costs of outside services, taxes, fees, capital costs, depreciation expense, interest expense, working capital expense, any costs of funds or other financing costs, and the costs of a reasonable reserve as
provided herein.
2. The Costs included in a WRAP Administration Charge assessed for a Month shall be the Costs determined as being incurred for that Month, including, without limitation, for each Month, one-twelfth of any annual charge(s).
3. The Costs included in the WRAP Administration Charge for a reasonable reserve
shall be those designed to establish over the first twelve months that this WRAP
Administration charge is in effect an amount equal to 6% of the expected Costs, exclusive of such reserve, for one year; and to maintain such reserve thereafter at an amount equal to 6% of the expected Costs, exclusive of such reserve for the then-current year. WPP shall record on its income statement deferred regulatory
expense, and WPP’s balance sheet will reflect as a cumulative deferred regulatory
liability, revenues collected under this Schedule 1 that are in excess of the Costs exclusive of such reserve and taking account of and including any accrued tax expense effects of this regulatory liability. The deferred regulatory liability will be reduced when after-tax WPP revenues collected under this Schedule 1 during any
Month are less than the Costs exclusive of such reserve. Within thirty days after
the end of each Year, to the extent WPP determines that the deferred regulatory liability exceeds 6% of WPP’s revenues that were collected under this Schedule 1 during such Year, such excess amounts in the deferred regulatory liability shall be refunded evenly over the applicable billing determinant volumes in the remainder
of the subsequent Year through credits to charges to then-current customers under
this Schedule 1.

Section 2. WRAP Administration Charge

Each Participant shall be assessed each Month a WRAP Administration Charge equal to the sum of the Base Charge and the Load Charge, where:

The Base Charge for each Participant equals the Base Costs divided by the number of Participants being assessed the Base Charge for the Month for which the WRAP Administration Charge is being calculated;
The Load Charge for each Participant equals the Load Charge Rate of the Load
Services Costs divided by the sum of the Median Monthly P50 Peak Loads of the Participants being assessed the Load Charge for the Month for which the WRAP Administration Charge is being calculated, times that Participant’s Median Monthly P50 Peak Load;

And where: Base Costs means the Costs for the Month of the Base Services Cost Centers shown in the WRAP Cost Assignment Matrix, plus the Base Services Percentage times the
Costs for that Month of the Dual Benefit Cost Centers shown below in Section 4:
WRAP Cost Assignment Matrix; Load Services Costs means the Costs for the Month of the Load Services Cost Centers shown in the WRAP Cost Assignment Matrix, plus the Load Services
Percentage times the Costs for that Month of the Dual Benefit Cost Centers shown
in the WRAP Cost Assignment Matrix; and Median Monthly P50 Peak Loads means, for each Participant, the median of the Monthly P50 Peak Loads used in the FS Capacity Requirement of such Participant
for two Binding Seasons corresponding to the two FS Submittal most recently
validated by WPP. If before or during a Binding Season, a Participant has need to update their Monthly P50 Peak Load for allowable reasons, those updated Monthly P50
Peak Loads will be replaced and the Median Monthly P50 Peak Load value
recalculated upon validation of the change in participating load. A Participant joining the Program will supply data such that WPP can validate Monthly P50 Peak Loads for the first two Binding Seasons for which the
Participant will submit an FS Submittal for use in calculating Load Services
Costs until these FS Submittals are submitted and reviewed in the normal timeframe.

Section 3. Maximum Charge Rates

3.1 Notwithstanding anything to the contrary in this Schedule 1, the sum of the Base Charges for all Months in a Year shall not exceed the Annual Maximum Base Charge of $59,000/Year, and the sum of the Load Charge Rates for all Months in a Year shall not exceed the Annual Maximum Load Charge Rate of $199/MW. WPP
shall, to the extent reasonably practicable, provide two-months’ notice prior to
WPP’s filing at FERC of an application to change the Maximum Base Charge or the Maximum Load Charge Rate, provided that nothing herein shall limit the Board of Director’s authority and discretion to seek at FERC a change in the maximum rates in the time and manner the Board determines in the best interests of the
Western Resource Adequacy Program. For purposes of clarity, these specified
maximum rates on the Base Charge and the Load Charge do not limit the level of the Cash Working Capital Support Charge established under Section 5 of this Schedule 1, nor do they limit the amount of the default Allocation assessment provided under Part I of this Tariff.

3.2 To facilitate Participant planning, the WPP shall prepare, and provide to the RAPC, good faith, non-binding estimates of: (i) reasonably anticipated WRAP budgets for three Years beyond the most recently approved WRAP budget, including sensitivity analyses for reasonably identified major contingencies; (ii) reasonably
anticipated numbers of Participants and MWs of Winter and Summer P50 Loads
for each such Year; and (iii) reasonably anticipated highest monthly Base Charges and Load Charge Rates for each such Year. All assumptions and estimates in such forecasts and analyses shall be in WPP’s sole discretion, which may be informed by RAPC discussion of such topics.

Section 4. WRAP Cost Assignment Matrix

(Participant engagement,

Section 5. Cash Working Capital Support Charge
5.1 In addition to the WRAP Administration Charge, each Participant shall be assessed
a Cash Working Capital Support Charge, to support WPP’s maintenance of sufficient funds on hand to make payments required for the operation and administration of the WRAP on a timely basis. Cash Working Capital Support Charges shall be designed to maintain a Cash Working Capital Fund that, at its
maximum level over a twelve-month cycle, equals approximately nine-twelfths of
the expected annual payment due from the WPP to the Program Operator for its Program Operator services.
5.2 A Participant shall pay a Cash Working Capital Support Charge no later than thirty days after that Participant executes a WRAPA. The Cash Working Capital Support
Charge due following WRAPA execution equals the Cash Working Capital Support
Charge Rate, calculated as the Cash Working Capital Fund at its required maximum twelve-month cycle level divided by the sum of the Median Monthly P50 Peak Loads of all Participants, times that Participant’s Median Monthly P50 Peak Load.
5.3 To the extent the Cash Working Capital Fund is adequately funded at the time a
new Participant executes a WRAPA, the revenue from such Participant’s payment
of the Cash Working Capital Support Charge shall be distributed to all Participants that previously have paid a Cash Working Capital Support Charge, pro rata based on the Median Monthly P50 Peak Loads of all Participants that have previously paid such charge.
5.4 To the extent, and at such time, WPP determines that an incremental addition to the
Cash Working Capital Fund is needed due to such causes as, for example, an expected increase in the annual payment to the Program Operator, each Participant shall be assessed an Incremental Cash Working Capital Support Charge equal to the desired incremental addition, divided by the sum of the Median Monthly P50
Peak Loads of all Participants being assessed the Incremental Cash Working
Capital Support Charge for the Month for which the Incremental Cash Working Capital Support Charge is being calculated, times that Participant’s Median Monthly P50 Peak Load.

ATTACHMENT A
Western Resource Adequacy Program Agreement
This Western Resource Adequacy Program Agreement (“Agreement”) dated as of _______________ (“Effective Date”) is entered into by and between Western Power Pool Corporation (“WPP”) and ______________________ (“Participant”). WPP and Participant are each sometimes referred to in the Agreement as a “Party” and collectively
as the “Parties.”
In consideration of the mutual promises contained herein, and other good and valuable consideration, the receipt of which is hereby acknowledged, the Parties agree as follows:
1. The Parties agree that this agreement shall be governed by the rates, terms, and conditions of the Western Resource Adequacy Program Tariff (“Tariff”) and all
such rates, terms, and conditions contained therein are expressly incorporated by
reference herein. All capitalized terms that are not otherwise defined herein shall have the meanings ascribed by the Tariff.
2. Participant wishes to participate in the Western Resource Adequacy Program (“WRAP”) administered by WPP under the Tariff.
3. Participant certifies that it satisfies all of the following qualifications:
3.1 Participant is a Load Responsible Entity as that term is defined in the Tariff.
3.2 Participant commits to complying with all applicable terms and conditions of WRAP participation as set forth in the Tariff and Business Practice Manuals adopted thereunder, including all Forward Showing Program and
Operations Program requirements.
4. Participant will register all resources and supply contracts and shall disclose any other obligations associated with those resources and supply contracts.
5. Participant represents and warrants that it is authorized by all relevant laws and regulations governing its business to enter into this Agreement and assume all rights
and obligations thereunder.
6. It is understood that, in accordance with the Tariff, WPP, as authorized by its independent Board of Directors, may amend the terms and conditions of this Agreement or the Tariff by notifying the Participant in writing and making the appropriate filing with FERC, subject to any limitations on WPP’s authority to
amend the Tariff as set forth therein.
7. Participant agrees to pay its share of all costs associated with the WRAP, as calculated pursuant to Schedule 1 of the Tariff. The manner and timing of such payment shall be as specified in Schedule 1 of the Tariff.
8. WPP agrees to provide all services as set forth in the Tariff.

9. Term and termination. This Agreement shall commence upon the Effective Date
and shall continue in effect until terminated either by WPP by vote of its Board of
Directors or by Participant’s withdrawal as set forth herein. WPP and Participant agree that participation in the WRAP is voluntary, subject to the terms and conditions of this Agreement and the Tariff. The date upon which a Participant’s withdrawal is effective and its participation in the program terminates is referred to
as the “Withdrawal Date.”
9.1 Normal Withdrawal: In general, Participant may withdraw from this Agreement by providing written notice to WPP no less than twenty-four months prior to commencement of the next binding Forward Showing Program period. Once notice has been properly given, Participant remains
in a “Withdrawal Period” until the Withdrawal Date.
9.1.1 During Participant’s Withdrawal Period, Participant remains subject to all requirements and obligations imposed by the Tariff and this Agreement, including but not limited to all obligations imposed in the Forward Showing Program and Operations Program and
obligation to pay Participant’s share of all costs associated with the
WRAP.
9.1.2 All financial obligations incurred prior to and during the Withdrawal Period are preserved until satisfied.
9.1.3 During the Withdrawal Period, Participant is not eligible to vote on
any actions affecting the WRAP that extend beyond the Withdrawal
Period.
9.2 Expedited Withdrawal: Participant may withdraw from this agreement with less than the required twenty-four month notice as set forth below. Participant shall negotiate with WPP regarding the timing of the Expedited
Withdrawal.
9.2.1 Extenuating Circumstances: The following such events and circumstances shall constitute “extenuating circumstances” justifying a withdrawal on less than twenty-four months. Participant invoking an extenuating circumstance shall negotiate with WPP
regarding potential ways to minimize the impact of the expedited
withdrawal on all other Participants and WPP. Such extenuating circumstances and any mitigation plan to minimize the impact of the expedited withdrawal must be reviewed and approved by the Board of Directors prior to termination of Participant’s WRAP obligations.
Regardless of the extenuating circumstance, all financial obligations
incurred prior to the Withdrawal Date remain in effect until satisfied.
9.2.1.1 A governmental authority takes an action that substantially impairs Participant’s ability to continue to

participate in the WRAP to the same extent as
previously; provided, however, that Participant shall be
obligated to negotiate with WPP regarding potential ways to address the impact of the regulatory action without requiring a full withdrawal of Participant from the WRAP if possible.
9.2.1.2 Continued participation in the WRAP conflicts with
applicable governing statutes or other applicable legal authorities or orders.
9.2.1.3 Participant voted against a RAPC determination and disagreed with a Board of Directors decision to release
composite or aggregated data under Section 10.2.1 of the
Tariff, provided that such right to expedited withdrawal is exercised promptly after the first time that the Board of Directors determines that the form and format of composite or aggregated data sufficiently protects
against the release of confidential or commercially
sensitive Participant data. Failure to exercise this right promptly upon the first occurrence of the Board of Directors voting on a specific form and format of composite or aggregated data shall constitute a waiver of
the right to expedited withdrawal for any future
disclosures of composite or aggregated data in the same or substantially similar form and format.
9.2.1.4 FERC or a court of competent jurisdiction requires the public disclosure of a Participant’s confidential or
commercially sensitive information, as further described
in Section 10.5 of the Tariff; provided however that such right to expedited withdrawal shall be exercised promptly upon the exhaustion of all legal or administrative remedies aimed at preventing the release.
9.2.2 Exit Fee: If the impact of Participant’s withdrawal on WRAP
operations can calculated with a high degree of confidence and mitigated by the payment of an “exit fee” to be calculated by WPP, an expedited withdrawal will be permitted. Such exit fee shall include (but not be limited to): (i) any unpaid WRAP fees or
charges; (ii) Participant’s share of all WRAP administrative costs
incurred up to the next Forward Showing Program period; (iii) any costs, expenses, or liabilities incurred by WPP and/or the Program Operator directly resulting from Participant’s withdrawal; and (iv) any costs necessary to hold other participants harmless from the
voluntary expedited withdrawal. The exit fee may be waived to the
extent that it would violate any federal, state, or local statute, regulation, or ordnance or exceed the statutory authority of a federal

agency. The exit fee shall be paid in full prior to the Withdrawal
Date.
9.2.3 Amendments to Section 3.4 of the Tariff: In the event that amendments to Section 3.4 of the Tariff are approved by the RAPC and Board of Directors, a Participant that voted against such a change may withdraw with less than the required twenty-four month
notice, provided that the Participant satisfy all obligations in the
Forward Showing Program and Operations Program and satisfy all other financial obligations incurred prior to the date that the amendments to Section 3.4 of the Tariff are made effective by FERC.
9.2.4 Expulsion: The Board of Directors, in its sole discretion, may
terminate Participant’s participation in the WRAP and may terminate this Agreement with Participant for cause, including but not limited to material violation of any WPP rules or governing documents or nonpayment of obligations. Prior to exercising such
right to terminate, the Board of Directors shall provide notice to
Participant of the reasons for such contemplated termination and a reasonable opportunity to cure any deficiencies. Such Board of Directors termination shall be after an affirmative vote consistent with the Board of Directors standard voting procedures. Such
termination shall not relieve the Participant of any financial
obligations incurred prior to the termination date, and WPP may take all legal actions available to recover any financial obligations from Participant.
10. No Waiver of Non-FERC-Jurisdictional Status. If Participant is not subject to the
jurisdiction of FERC as a public utility under the Federal Power Act, Participant
shall not be required to take any action or participate in any filing or appeal that would confer FERC jurisdiction over Participant that does not otherwise exist. Participant acknowledges that FERC has jurisdiction over the WRAP, including Participant’s activities in the WRAP.

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