WAPA Energy Planning and Management Program — Integrated Resource Planning for Federal Hydropower Customers
The Western Area Power Administration (WAPA) is one of five federal Power Marketing Administrations (PMAs) within the Department of Energy — agencies that market and transmit electricity generated at federal hydropower projects in their regions. WAPA markets power from federal dams across 15 western states (California, Arizona, Nevada, Colorado, Utah, Wyoming, Montana, Nebraska, South Dakota, North Dakota, Kansas, Oklahoma, Texas, New Mexico, and Minnesota), serving approximately 700 wholesale customers — rural electric cooperatives, municipal utilities, state agencies, and Native American tribes — through a transmission network of over 17,000 miles of high-voltage lines. The Energy Planning and Management Program (EPAMP), codified at 10 CFR Part 905, implements Section 114 of the Energy Policy Act of 1992, which requires WAPA's wholesale customers to prepare Integrated Resource Plans (IRPs) — long-range plans that evaluate the full range of energy resource alternatives, including demand-side management and renewable energy, before acquiring new power resources. The regulation also establishes WAPA's Power Marketing Initiative for competitive bidding on new federal power contracts.
Current Rule (2026)
| Parameter | Value |
|---|---|
| Citation | 10 CFR Part 905 |
| Issuing agency | Western Area Power Administration (WAPA), Department of Energy |
| Statutory authority | 42 U.S.C. §§ 7275–7276 (Energy Policy Act 1992, §§ 113–114) |
| Who must comply | WAPA customers with purchase power agreements (PPAs) |
| IRP submission timeline | Within 3 years of program effective date (initial); every 5 years (update) |
| Small customer alternative | Available for utilities below WAPA-defined small customer threshold |
| Last major amendment | 1994 (59 FR 14264) |
Legal Authority
- 42 U.S.C. §§ 7275–7276 (Energy Policy Act of 1992, §§ 113–114) — Requires Western Area Power Administration (WAPA) and other federal power marketing administrations to implement Integrated Resource Planning for their power customers; conditions access to federal power on customer compliance with IRP requirements
- 10 CFR Part 905 — DOE/WAPA implementing regulations for the Integrated Resource Planning program; specifies IRP content requirements, filing timelines, public participation obligations, and WAPA's review and approval process for customer IRP submissions
Key Mechanics
10 CFR Part 905 implements the Integrated Resource Planning (IRP) requirement that the Western Area Power Administration (WAPA) — the DOE power marketing administration serving 15 western states — imposes on its utility and cooperative customers as a condition of receiving low-cost federal hydropower. WAPA sells power generated by federal dams (primarily Bureau of Reclamation and Army Corps of Engineers projects in the Colorado River and Missouri River basins) at cost-based rates significantly below wholesale market prices. Congress conditioned access to this subsidized power on customer compliance with IRP under 42 U.S.C. §§ 7275–7276: utilities holding long-term WAPA power purchase agreements must periodically develop and submit Integrated Resource Plans documenting: (1) a full assessment of current and projected future customer load; (2) an evaluation of all supply-side and demand-side resources capable of meeting load (including energy efficiency, conservation, and renewable energy); (3) a preferred resource portfolio; and (4) a public participation process in IRP development. WAPA reviews submitted IRPs for compliance with Part 905 requirements; noncompliant utilities risk losing access to their WAPA power allocation. The IRP process is the primary mechanism by which the federal government uses its role as low-cost power supplier to incentivize comprehensive resource planning among western utilities, many of which are rural electric cooperatives that otherwise would face little regulatory pressure to evaluate demand-side alternatives.
What This Rule Does
WAPA sells federally generated hydropower at cost-based rates that are far below wholesale market prices — a significant subsidy to the utilities and cooperatives that hold long-term purchase power agreements (PPAs) with WAPA. Congress attached the IRP requirement to WAPA power contracts as a condition for access to this low-cost federal power: if you want discounted hydropower from federal dams, you must plan comprehensively for your customers' energy needs rather than simply buying the cheapest power available without considering efficiency or conservation alternatives.
The IRP process requires each WAPA customer to evaluate the full range of resource alternatives — including demand-side management (efficiency programs, interruptible service, load management), renewable energy, and conventional supply resources — and select those that best meet forecast demand at the lowest cost while incorporating environmental and social values. The IRP is not just a planning document submitted to a file; it must drive actual resource acquisition decisions. WAPA reviews the IRP to determine whether the customer has genuinely considered alternatives before acquiring new power resources.
Part 905 also governs WAPA's Power Marketing Initiative (Subpart C), a framework for competitive bidding when WAPA renews or reallocates power contracts under its marketing criteria rather than the traditional administrative preference for existing preference customers.
Key Provisions
- § 905.10 — Who must comply: every WAPA customer must address IRP and alternatives in its long-term resource planning; customers with purchase power agreements must submit an IRP, a small customer plan, or a minimum investment report depending on the customer's size and load characteristics
- § 905.11 — IRP content requirements: an IRP must evaluate the full range of resource alternatives — demand-side management, renewable energy, distributed generation, and conventional supply — and select the lowest-cost portfolio consistent with reliability and environmental goals; the IRP must include: (a) a load forecast for the planning horizon; (b) a description of all resource alternatives considered; (c) the process used to evaluate alternatives; (d) the preferred resource plan with justification; (e) any demand-side management programs planned or underway; and (f) an environmental assessment of the proposed resource mix
- § 905.12 — IRP submission: one IRP is required per customer regardless of how many long-term power contracts the customer holds with WAPA; customers with contracts at multiple WAPA Regions may coordinate a single IRP that addresses all their WAPA relationships; IRPs must be submitted to the relevant WAPA Regional Office
- § 905.13 — IRP timing: customers that have not previously had an IRP approved by WAPA must submit an initial IRP within 3 years of the regulation's effective date (or within 3 years of signing a new long-term PPA); after initial approval, IRPs must be updated every 5 years; WAPA may grant extensions for good cause
- § 905.14 — Annual progress reports: WAPA requires annual IRP progress reports; customers must submit progress reports each year within 30 days of the anniversary date of their currently approved IRP; the progress report must describe implementation status of the resource plans identified in the IRP and any material changes in load forecast or resource availability
- § 905.15 — Small customer plan alternative: customers below WAPA's small customer threshold may submit a small customer plan instead of a full IRP; a small customer plan is a shorter document demonstrating that the customer has considered demand-side management and renewable options appropriate to its size; WAPA reviews whether the customer's plan reflects genuine engagement with alternatives
- § 905.16 — Minimum investment report alternative: customers that already have a low-emissions resource mix or very low growth in energy demand may demonstrate this through a minimum investment report rather than a full IRP; the report must show that the customer's existing resource mix meets the IRP's environmental and efficiency goals without additional investment
- §§ 905.30–905.36 — Power Marketing Initiative: WAPA's framework for competitive allocation of federal power when existing contracts expire and new power is available for marketing; establishes the criteria for competitive bidding, customer eligibility, bid evaluation, and contract terms for new power allocations under competitive processes; this is distinct from WAPA's traditional administrative reallocation process, which follows Reclamation-law preference rules for municipal and cooperative utilities
How It Affects You
If you are a municipal utility, rural electric cooperative, or public power entity in the West: your eligibility for low-cost WAPA hydropower comes with the IRP requirement attached. If you hold a WAPA PPA, check whether your contract includes a reference to 10 CFR Part 905 compliance — most post-1994 PPAs do. WAPA's IRP reviews are not pro forma: utilities that submit inadequate plans (load forecasts without demand-side analysis, no evaluation of renewable alternatives) have faced requests for supplemental information and delays in contract renewal. The IRP is also useful internally — utilities that have completed thorough IRPs often use them as the basis for rate cases before state regulatory commissions. If your utility qualifies as a small customer, the small customer plan is substantially less burdensome while still satisfying the statutory requirement.
If you work in energy policy or utility planning in the western states: WAPA's IRP requirement is one of the few federal mandates that requires western public power utilities — which are often exempt from state IRP requirements applicable to investor-owned utilities — to engage in long-range resource planning. Rural electric cooperatives in the Dakotas and cooperative utilities in Colorado and Wyoming that are not subject to comprehensive state utility commission oversight are nonetheless required to conduct IRP analyses as a condition of their federal power contracts. The demand-side management and renewable energy requirements in the IRP standard have pushed some smaller utilities toward efficiency programs and solar/wind procurement that they might not have undertaken without the federal requirement.
If you are a developer of renewable energy or demand-side resources in WAPA's service territory: utilities subject to the Part 905 IRP requirement must evaluate renewable alternatives in their resource planning process. If you can provide data on the cost and availability of your resource in the WAPA territory, utilities incorporating your resource into their IRP analysis are more likely to eventually procure it. The IRP process creates a pathway for renewable developers to engage with public power utilities that might otherwise have limited incentive to proactively consider alternatives.
Statutory Authority
This rule implements:
- 42 U.S.C. § 7275 (Energy Policy Act 1992, § 113) — declares congressional policy that western federal power customers should undertake integrated resource planning to minimize costs and adverse environmental effects; provides definitions for the IRP program
- 42 U.S.C. § 7276 (Energy Policy Act 1992, § 114) — requires WAPA and other PMAs to establish programs requiring customers to develop IRPs; conditions access to federal power on customer compliance with IRP requirements; authorizes the Secretary of Energy to promulgate regulations implementing the IRP program; grants WAPA authority to establish power marketing criteria including competitive bidding processes
Recent Rulemakings
The Part 905 regulations were promulgated in 1994 (59 FR 14264, March 25, 1994) implementing the Energy Policy Act 1992 requirements. No major amendments since 1994. The IRP standards and customer obligations have been administratively stable, though WAPA has issued policy guidance on the interaction between the IRP program and subsequent clean energy initiatives (including the Biden administration's Western Renewable Energy Zones project and transmission expansion plans). WAPA's power marketing criteria and competitive bidding frameworks have evolved through administrative policy changes rather than CFR amendments.