Recently, high temperatures and adverse weather conditions impacted wholesale electric market activity in the Western Electricity Coordinating Council (WECC). In multiple orders, the Commission has stated that spot market sales above the soft energy price cap in WECC outside of the California Independent System Operator Corporation (CAISO) are subject to justification and refund, and that cost justification must be filed within seven days after the end of the month in which the excess sale occurred. In recognition that regulated entities may require additional time to submit cost justification, the Commission extended the reporting deadline for cost justification filings related to sales that took place in August, 2020, from September 8, 2020, to October 7, 2020.
The Commission cannot anticipate all of the possible bases on which a supplier may seek to justify exceeding the WECC soft energy price cap. Accordingly, the Commission has declined in the past to define the justification required, noting that it cannot pre-determine the specific form of demonstrations and associated types of documentation a seller might provide. However, staff recognizes that entities, including sellers, have questions about how to best make the required cost justification filings. In recognition of these questions, staff has developed this guidance regarding the WECC soft energy price cap and filings that sellers could submit to justify sales above that cap. The guidance provided here was prepared by staff; it is informal, does not necessarily reflect the views of the Commission itself, and is thus not binding on the Commission. Furthermore, this guidance does not prejudge whether any sales above the WECC soft energy price cap during the period in question may be justified.
 E.g., Western Elec. Coordinating Council, 133 FERC ¶ 61,026, at P 1 (2010) (establishing a $1000/MWh soft price cap in the WECC outside CAISO, effective April 1, 2011); Cal. Indep. Sys. Operator Corp., 100 FERC ¶ 61,060, at P 46 (July 2002 Order), order on reh’g, 101 FERC ¶ 61,061, at P 17 (2002) (October 2002 Order) (establishing a price cap in CAISO and WECC and clarifying that bids above the cap will be subject to justification and refund).
 Notice of Extension of Time re Western Electricity Coordinating Council under EL10-56, August 31, 2020.
 Western Elec. Coordinating Council, 133 FERC ¶ 61,026, at P 16 (2010)
 San Diego Gas & Electric Co. v. Sellers of Energy an Ancillary Services Into Markets Operated by the Cal. Indep. Syst. Operator and the Cal. Power Exchange, et al., 93 FERC ¶ 61,121 (2000).
 July 2002 Order, 100 FERC ¶ 61,060 at P 46.
 E.g., October 2002 Order, 101 FERC ¶ 61,061 at P 17; see also Western Elec. Coordinating Council, 133 FERC ¶ 61,026, at PP 14, 16 (2010) (October 2010 Order).
 October 2010 Order, 133 FERC ¶ 61,026 at P 1.
October 2010 Order, 133 FERC ¶ 61,026, at P 1; see also Cal. Indep. Sys. Operator Corp., 101 FERC ¶ 61,061 (2002).
 San Diego Gas & Elec. Co., v. Sellers of Energy & Ancillary Servs. Into Markets Operated by the Cal. Indep. Syst. Operator & the Cal. Power Exchange, 95 FERC 61,115, at 61,539 (2001).