Docket Nos. ER22-2762-000, ER22-2762-001
I concur in approving this FPA section 205 proposal because it represents the creation of a new and, most importantly, voluntary structure to promote resource adequacy within the Western states covered by this proposal. The record shows that the organizations representing the state regulators and other policy-makers in the affected states have consented to the proposal, including its governance structure.[1] The record shows no states or state organizations filed in opposition.
This proposal as filed does not include binding participation in any specific power markets or in any specific RTO, existing or to be created. Whether the states in the non-RTO West choose to allow or require their regulated utilities to participate in specific power markets or RTOs will be decisions for the elected and duly-appointed policy-makers in these Western states to make, not for the Commission to impose on them. It is the elected and duly-appointed state officials, including state utility regulators, who represent the public interest in their states, and it will ultimately be their decision whether or not this voluntary construct for resource adequacy evolves into more, such as participation in specific power markets or new or existing RTOs.
For these reasons, I respectfully concur.
[1] See, e.g., CREPC Comments at 1, 3 (noting strong support for the WRAP and indicating that the WRAP was the result of a collaborative effort between stakeholders across the West, including state representatives).