Western Power Pool outlines plan for RAP to become binding in winter 2027–28; participants face data, capacity and timing hurdles

Michael O'Brien, senior policy and engagement manager for the Western Power Pool, told the Regional Transmission Coordination Task Force on Sept. 23 that the Western Resource Adequacy Program (RAP) is currently nonbinding — the tariff and supporting business-practice manuals are active, but enforcement charges for failing compliance are not yet in effect.

O'Brien said the program has two linked time horizons. The planning piece is a forward showing, where participants submit monthly portfolios and are assigned planning reserve margins (PRMs) seven months before a season; the operations piece runs during the season and is intended to match surplus capacity to deficits among participants. "By planning together, collectively, we should need lower planning reserve margins," he said.

RAP participants who sign on are treated as load-responsible entities and must follow qualifying-capacity (QCC) methods that determine how resources such as wind, solar and storage count toward a participant's capacity obligations. O'Brien said the QCC determinations and the program's analytical metrics are designed to deliver a consistent, regional 1-in-10 reliability standard.

On timing, O'Brien said participants agreed to a default first binding season of winter 2027–28. Because the RAP includes a two-year exit provision, participants that do not want to be in the first binding season must notify the program by Oct. 31, 2025. He also said the program includes a soft-landing: "during those initial binding seasons from winter '27-'28 on, for the first four I believe there will be discounts on any deficiencies that are incurred," giving participants a ramp into enforcement.

Task-force members pressed O'Brien for concrete examples of RAP in action this past summer. He said the program operator (SPP) is already running the forward-showing and operations accounting processes for participants, and participants are tracking operational data, but the program has not yet been used in a binding way to dispatch or to deliver surpluses to deficits. "So that's still a work in progress," he said.

O'Brien identified three principal near-term implementation challenges: (1) a significant data and administrative lift to get detailed resource, contract and performance data to the operator for validation; (2) insufficient capacity for some participants to meet the program's metrics, which in part explains reluctance to go binding; and (3) the timing of forward-showing metrics — participants currently learn their forward-showing PRMs a year before they do the showing, creating uncertainty. RAP task forces are working on earlier PRM release and on day-ahead market optimization concepts intended to reduce uncertainty and PRM volatility.

On onboarding and withdrawal, O'Brien described an "onboarding" BPM (business practice manual) that includes limited data requests and an advanced assessment process; he warned that it can take up to two years for some data and QCC effects to be reflected in PRMs. He also outlined two withdrawal paths: a standard withdrawal that leaves a participant in the program for two years, and an expedited withdrawal that would require negotiation about compensation for the remaining participants.

O'Brien said WPP and participants held a closed in-person meeting in Seattle in mid-September to surface concept papers and address Oct. 31 timing pressures, and he promised follow-up outreach. The task force did not take formal action on RAP at the meeting; members were told staff would report back as task forces and work plans advance.

The chair closed the session by thanking O'Brien and noting staff would follow up on Nov. 1 about participation and the Oct. 31 deadline.