PORTLAND, Ore. — PacifiCorp has asked the Western Power Pool’s Board of Directors to allow Western Resource Adequacy Program participants to defer their decision to commit to the program’s binding phase by at least one year, saying the emergence of day-ahead markets in the West and other developments warrant reconsideration.

Following a question during a panel discussion at a Western utility conference about PacifiCorp’s position on WRAP, Michael Wilding, vice president of energy supply management at PacifiCorp, said WRAP “is an incomplete product.”

“We see the value in the regional coordination,” Wilding said at the fall joint meeting of the Committee on Regional Electric Power Cooperation and Western Interconnection Regional Advisory Body (CREPC-WIRAB) in Portland. “We want to continue to work with the region. But right now, we need … some time to evaluate where the program’s going.”

Wilding’s comments came in response to a question about a letter issued by PacifiCorp on Sept. 30 in which CEO Cindy Crane said moving forward with the current Oct. 31 commitment date “would be imprudent and not in the best interest of our customers.”

The letter came one day after WPP announced that WRAP is moving forward with the first binding season in winter 2027/28 after receiving commitments from a “critical mass” of participants. (See related story, WRAP ‘Binding’ Phase Set for Winter 2027/28 After Utilities Affirm Commitment.)

Crane noted in the letter that work by the WRAP Day-Ahead Market (DAM) and Planning Reserve Margin (PRM) task forces highlights developments that have emerged after WRAP was formed and that the program must now adapt to.

For example, the DAM Task Force is developing a proposal aimed at realigning WRAP’s “operational subregions with the footprints of CAISO’s [Extended Day-Ahead Market] and SPP’s Markets+, replacing the legacy MidC/SWEDE structure,” the letter stated.

“This would fundamentally change how capacity planning, the operational program, and the settlement of holdback and energy deployments are managed,” according to Crane.

Additionally, the PRM Task Force is considering new tools for setting planning reserve margins, which could impact participants, Crane contended.

“Active discussions are occurring relating to mechanisms to defer deficiency charges for entities making strategic investments in new resources, recognizing the need for flexibility as the region transitions to new market structures,” according to the letter.

Crane urged the board to defer the binding decision by at least one year to implement changes and allow for further stakeholder input.

WPP told RTO Insider that the organization’s board and staff are reviewing the letter.

WPP launched the WRAP in response to industry concerns about resource adequacy in the West.

Under the program’s forward showing requirement, participants must demonstrate they have secured their share of regional capacity needed for the upcoming season. Once WRAP enters its binding phase, participants with surplus capacity must help those with a deficit in the hours of highest need. (See WRAP Task Force Explores Optimization for Day-ahead Markets.)

The binding phase also includes penalties for participants that enter a binding season with capacity deficiencies compared with their forward showing of resources promised for that season.

In 2024, the binding phase was postponed by one year at the request of participants, who said they were facing challenges including supply chain issues, faster-than-expected load growth and extreme weather events that would make it difficult for them to secure enough resources and avoid penalties. WRAP members voted in September 2024 to delay the binding phase until summer 2027, but that date was pushed forward. (See WRAP Members Vote to Delay ‘Binding’ Phase to Summer 2027.)

‘Some Folks Will Leave’

Speaking on a separate Oct.1 panel at the CREPC-WIRAB conference, WPP Chief Strategy Officer Rebecca Sexton did not mention the PacifiCorp letter, but acknowledged the challenges facing the WRAP, saying the program is “living in a world of dichotomies” in which “lots of things are true at the same time.”

“We are in a resource adequacy crisis, and we also have utilities who are working really hard to close the gap, working really hard, and it feels like the goalposts keep moving with all of these challenges,” she said.

In her presentation, Sexton spelled out the top five challenges facing WRAP members — many of which had been cited by participants in their previous request for a delay, including: “significant” load growth, supply chain constraints for project developers, interconnection delays for resources, resource retirements and fuel supply issues.

Sexton said part of the program’s “value proposition” is its binding forward showing, which tells participants how much capacity they must bring to the table to meet regional needs. The binding operational program is the other part, enabling participants with surpluses to assist those with deficits in the hours of highest need.

“So when the operating time horizon is similar, we motivate the participants to deliver to each other. If you’re having a better day than planned, then you might get an obligation to deliver to someone who’s having a worse day than planned,” Sexton said.

She pointed out that while participation in the WRAP is voluntary, once committed, participants are expected to meet their obligations to avoid a “tragedy of the commons situation” in which some participants lean too heavily on others to meet their own needs.

Sexton noted that WRAP participants are working “to evolve the program to make sure that it’s one they want to stay in” and “that they think is really solving this regional need.”

She pointed to various WRAP efforts, including stabilizing planning reserve margins to make them more predictable and working to “best integrate” with day-ahead markets to optimize delivery, which she called a “real opportunity” for the program.

But Sexton acknowledged yet another “dichotomy” facing WRAP: that “the reason why we need the resource adequacy program is also increasing, and it’s really challenging to subject yourself to this voluntary compliance program and get the resources in place to meet the metrics.”

“So we are having conversations [with participants]. We expect that some folks may not stay in the program. We know some folks will leave,” she said.