APS is supportive of the Task Force Schedule as outlined in Figure 3. This schedule is aligned to the prioritization ordered by stakeholders during the January 2025 PRC.

PacifiCorp appreciates the time and robust collaboration amongst PRC stakeholders to arrive at the 2025 PRC workplan and values the opportunity to comment. PacifiCorp views binding WRAP Participation as a serious commitment with significant repercussions associated with non-compliance. Program efforts to reduce uncertainty of the FS Capacity Requirement should be prioritized as current Participants approach a financially binding phase. Addressing uncertainty and volatility associated with core elements of the program, such as those outlined in 2024-CRF-002 should take priority in 2025. PacifiCorp acknowledges not all uncertainty can be addressed in this round of changes, and certainly not entirely within 2025. With the resources available to the program, and given the Workplan Development and Approval timeline as provided in BPM 301, PacifiCorp views the remainder of the current schedule to be reasonable.

No response submitted.

NV Energy appreciates the opportunity to comment on the 2025 Draft PRC Workplan and offers the following comments for consideration. NV Energy recommends that the PRC revise the Task Force Schedule to prioritize change requests that address uncertainty in the Forward Showing program before other high priority change requests. WRAP has yet to achieve binding program participation and should strive to provide more certainty towards the Forward Showing Metrics before prioritizing changes to the load forecast metrics. Forward Showing Metrics and Monthly PRMs have dramatically varied with every new calculation. Change request #2 “Earlier FS Metrics/ Monthly PRM Volatility” addresses the current Forward Showing uncertainty regarding PRM volatility and metric timing and provides participants with more confidence when planning for future seasons. Therefore, NV Energy recommends that change request #2 be moved into the schedule for 2025.

TEA is in favor of re-prioritizing CONCEPT 02 – EARLIER FS METRICS / MONTHLY VOLATILITY (PRM) from the 2026 Task Force workstream to the to 2025 Task Force workstream. To accommodate this re-prioritization, TEA would be in favor of moving CONCEPT 05 – LOAD GROWTH FACTOR to the 2026 Task Force workstream. Alternatively, depending on the expected go-live of SPP’s Markets+ day-ahead market (M+), work on CONCEPT 01 – DAM OPTIMIZATION as it specifically relates to M+ could potentially be pushed out to the 2026 workstream. TEA’s main driver for this re-prioritization is that the monthly PRM volatility that currently exists in the non-binding program is making it difficult to secure sufficient qualifying capacity to meet program requirements, particularly for shoulder months. Ensuring that TEA is resource adequate is the top concern for TEA and its participating utilities when it comes to participation in the binding program.

Seattle appreciates the opportunity to comment on the Draft PRC Workplan, Task Force Schedule found in Figure 3 – Level of Effort Review Draft Task Force Schedule and understands that there needed to be a balance of staff's time between, the PA (WPP), PO (SPP), plus participant involvement in each concept's timeline. Although these were ranked using an online tool, Seattle feels like the DAM Optimization/SWEDE TX Limits, should be moved out of the 2025 schedule and replaced with number 24 Flat load and PRMs and/or number 02 Earlier FS Metrics/ Monthly volatility. Optimization in the DAM market is an indirect variable of the WRAP program where Flat Load and PRMs and Earlier FS Metrics/ Monthly PRM Volatility are directly related to how the WRAP program operates and functions and WRAP should prioritize issues that deal first with WRAP directly like the PRMs, FS metrics, and so on vs DAM optimization work as this may not pertain to all participants. Resource adequacy and reliability are two focus areas for WRAP, not DA optimization.

PSE recommends establishing an arbitration process or dedicated task force to efficiently resolve matters like those outlined in 2024-CRF-014 regarding the Flexibility of Jointly-owned Resources. Rather than requiring a lengthy multi-year review cycle, many of these issues could be addressed through a streamlined process where a specialized task force reviews the matter and recommends appropriate documentation updates. This approach would not only expedite resolution of such issues but would also help manage the workplan more effectively by allowing more urgent matters to be prioritized for active consideration.

As WRAP Participants gain more experience from multiple non-binding seasons, it has become clear that the volatile nature of the monthly Planning Reserve Margins has created challenges for entities to anticipate the program requirements for the purposes of their resource plans. Further, many (if not most) Participants need to begin their resource planning processes before the PRMs for the planning period have been finalized. As such, Powerex would recommend that the PRC consider swapping topic 02: Earlier FS Metric/Monthly Volatility, and topic 05: Load Growth Factor, such that Topic 02: Earlier FS Metrics can be addressed earlier in the work schedule. We would note that we still see the Load Growth Factor as an important topic. However, based on conversations with other participants, it seems that looking into the stabilization of the PRMs merits being moved ahead in the work plan.

Idaho Power supports prioritizing Concept 02, the NVE/IPC-sponsored concept on earlier FS metrics and monthly PRM volatility, such that it is addressed in 2025, rather than waiting until 2026. Idaho Power believes this is a high-priority need for resolution that, if not timely resolved, could create hurdles for program implementation. Idaho Power believes that Concept 02 should be prioritized above or at least equal to any of the concepts currently slated for 2025. In Idaho Power’s view, the highest priority should be placed on concepts that mitigate unnecessary hurdles to program implementation. The goal of Concept 02 is to do just that: introduce stability and consistency into program metrics, including PRMs, and mitigate the monthly volatility that can occur with the current monthly PRM calculations. Both these issues can have a significant impact on participants’ forward showing demonstrations and ability to comply. While the concepts slated for 2025 are important and could provide benefit, Idaho Power believes Concept 02 could significantly mitigate implementation hurdles and should be addressed this year.

PGE supports all proposed changes and appreciates the opportunity to provide comments. While all proposed changes are important and PGE expects that they will enhance the program's design, PGE considers Concept 02 to be crucial to be implemented as soon as possible and proposes moving it up to the 2025 work plan. Additionally, PGE finds Concept 12 very important and believes it should be completed well before the first WRAP binding season to ensure the contribution of existing VERs is accurately reflected. Therefore, PGE would propose that Concept 12 is also moved up to 2025. To accommodate for these changes, PGE suggests switching Concepts 05 and 03 to the 2026 workplan. PGE also expresses its concerns regarding the impacts that emerging day-ahead markets, such as EDAM, scheduled to go live in 2026, will have on WRAP. Addressing these impacts in an accelerated manner is essential, as there may be inconsistencies between the setup of these markets and the design of WRAP that need to be resolved before the WRAP first binding season.

Salt River Project Agricultural Improvement and Power District (SRP) appreciates the clarity and structure of the Task Force schedule and the opportunity it provides to make meaningful progress on the identified concepts. SRP supports the flexibility built into the schedule and encourages the WPP to continue to monitor whether the pace of work aligns with the needs of WRAP participants as they prepare for binding participation. SRP also encourages early confirmation of Task Force participants to promote engagement and help participants plan accordingly.

The Draft Task Force Schedule identified in figure 3 was created by the PRC as a prioritization of concepts submitted through Change Request Forms in December 2024. Bonneville appreciates the Western Power Pool’s leadership in this process and has participated in and continues to support WRAP in general and this PRC prioritization process specifically. Bonneville also recognizes that the industry is in a period of significant change with the ongoing development of Day Ahead Markets (DAM). Both priorities and concepts addressed by WRAP will at times need to be adjusted accordingly. Bonneville proposes the program should work toward providing as much certainty as possible by October of this year on how the program will interact with organized markets and operate in binding seasons. Bonneville encourages the PRC to be flexible enough to adjust the annual plan as issues become priorities or new issues overtake those that have been identified and prioritized in the plan. Since this workplan was approved, the timeline associated with certain EDAM participants has become clear for a start in 2026. In addition, Bonneville’s scoping of future market implementation with the very real possibility that portions of our generation and load will be in different markets has revealed it is imperative to make sure WRAP integrates well with DAMs (regardless of which market a WRAP participant plans to join). WRAP must provide clarity of how its participants meet program compliance requirements (holdback and energy deployments) when load and generation are in different markets. This will require adjustments to the WRAP program. Bonneville believes the PRC work plan identifies many of the known issues and appropriately prioritizes them. We want to highlight the importance of Concept 01 that directly takes on some of the organized market issues and encourage the PRC to expand this concept’s scope, so as to address several other DAM/WRAP interface concerns beyond WRAP holdbacks and SWEDE transmission limits. Bonneville also wants to call attention to Concept 02, which deals with FS metrics (PRM) and the extreme volatility this is causing from month to month in the program. We recognize that both are prioritized below Concept 05 that deals with Load Growth Factors. As issues have evolved in Bonneville’s scoping of DAM implementation since the January PRC approval of this plan, we see these both as having greater effects on participants continuing to be able to participate in the program. While Concept 05 is highly important, we view it as something that must be updated but may be a lower priority when considering the decision points that are coming for participants in October 2025 and January 2026. Bonneville asks that Concept 01 be expanded, Concept 02 be moved up to July of 2025 and Concept 05 be delayed into 2026.