APS supports the current prioritization as a reflection of the January PRC meeting but has heard that the CRF 2 on Earlier Forward Showing Metrics may be something other WRAP participants are looking at as a potential deciding factor for participation. APS would like WPP and the PRC to consider if this is accurate before re-arranging. From APS’ perspective the proposal wouldn’t be implemented in time to make a difference for a Summer 2027 binding decision in January of 2026. APS isn’t opposed to the Concept but is unsure if changing the prioritization would be warranted at this juncture and would prefer to keep the DA Optimization effort as a higher priority based on current understanding. APS supports CRF 5 on Load Growth Factor being addressed in 2025 as proper load forecasting is critical to understanding how many resources are necessary to maintain adequacy, as well as the equitable treatment of entities within the program.

No response submitted.

No response submitted.

No response submitted.

No response submitted.

Prioritizing issues that are indirectly related to the WRAP program could impact participants binding commitments, non-participants from joining, and cause participants to flee WRAP, if WRAP places a lot of emphasis on external Day Ahead market integration/optimization, before we have the WRAP program ironed out and up and running.

PSE proposes consolidating the task force items currently listed under 2024-CRF-002, 2024-CRF-005, and 2024-CRF-24 into a single comprehensive long-term workplan item, given their closely interrelated nature. This consolidation would allow for a more coordinated and efficient approach to addressing these interconnected matters. We would like to take this opportunity to recognize the importance of developing a comprehensive regional load and resource forecasting practice to enhance long-term regional planning standards. In order to expedite and avoid delays in getting a binding program up and running, we recommend utilizing existing historical P50 calculations without load growth adjustments, particularly as these relate to seasonal planning just three months from the cure period deadline. We propose that a task force is setup for accomplishing the long-term load and resource forecasting objectives and standards. Therefore, we recommend reclassifying these CRF items to the "Long" Time Score category. This would allow prioritizing more urgent items that directly impact compliance for the upcoming binding season, rather than focusing on longer-term planning elements at this time.

No response submitted.

No response submitted.

Consolidated Concept 02 (Earlier FS Metrics / Monthly Volatility): The draft PRC Workplan proposes a timeline for completing this concept by June 2026. This timeline addresses the issue after October 2025, the deadline for changing the first binding season, and does not provide sufficient assurance that the PRMs applied to Winter and Summer shoulder months (i.e., June, September, November, March) will be reasonable when the program becomes binding. Runaway PRMs of up to nearly 30% during WRAP shoulder months and the PRM volatility between Advance Assessments pose significant risks to PGE's ability to plan adequately and meet WRAP capacity requirements during those months. The monthly PRM volatility can also lead to financial exposure from either a WRAP deficiency charges, or term capacity contracts needed to cover oversized peak load forecasts during WRAP seasons shoulder months that we would not expect in operations. The PRM uncertainty is an important factor in PGE’s decision to maintain the first binding season as Winter 2027-2028. To resolve this issue, along with the consolidated Concept 15 – Planned Outage Clarification, the program could consider reducing the number of days or entirely removing the shoulder months (i.e., June and September, and November and March, respectively) from the Summer and Winter WRAP seasons. Consolidated Concept 12 (ELCC by Vintage, Indicative QCC for LTS): PGE strongly supports the proposed changes in this concept, emphasizing their critical importance for implementation before the first binding season. Similar to Concept 02, the draft PRC workplan aims to complete this change by June 2026. However, this timeline does not align with the decision to maintain the first binding season due in October 2025. PGE advocates for the design change to ensure that the capacity contribution of existing variable energy resources (VERs) remains unaffected by the penetration of other VERs. Instead, only the capacity contribution of new VERs should be impacted. The current WRAP design can lead to QCC variations for existing resources, potentially reducing participants' resource supply QCCs even if their portfolios remain unchanged. Consolidated Concept 01 (DAM Consolidation/SWEDE TX Limits): WRAP design needs to align with day-ahead market (DAM) requirements. Therefore, any DAM-related enhancements should be prioritized, and WRAP design should remain flexible to accommodate potential changes as day-ahead markets come online as early as 2026. Unresolved design inconsistencies between WRAP and day-ahead markets before the first binding season could impact PGE’s decision to participate. Consolidated Concept 15 (Planned Outage Clarification): Utilities typically schedule planned outages during months with lower expected loads, including WRAP shoulder months such as June, September, November, and March. The combination of these planned outages and the extremely high PRMs calculated for these months often results in a deficit position in the WRAP Forward Showing, leading to potential significant deficiency charges. PGE emphasizes the importance of resolving and implementing this proposed change well in advance of the first binding season FS submittal.

SRP encourages the WPP to continue evaluating whether any concepts could affect participants ability or confidence to commit to binding participation. SRP appreciates the WPP’s willingness to remain open to accelerated or modified scheduling if needed to address unforeseen items that may require resolution(s). SRP recognizes comments from others that request prioritization of Concept 02. We believe that the PRC should strongly consider these requests and demonstrate flexibility and responsiveness to concerns as they emerge and become more urgent. SRP understands that some stakeholder comments request that this proposal be prioritized above Concept 05 (an item built from SRP request). SRP does not object to the PRC adjusting the prioritization in a way that resolves other concerns prior to Concept 05. In harmony with the results of the prioritization exercise in January, SRP advocates for Concept 05 to be included in this Workplan, as SRP believes that the consideration of this concept will be highly valuable in preserving WRAP integrity. SRP also recognizes comments discussing the prioritization of Concept 01, and SRP also sees value in maintaining this item as a priority, as resolution of several concerns may influence Participant comfort with Binding operations. While SRP has submitted Concepts that are included in the Workplan, SRP’s commitment to go Binding and continued participation in WRAP are not contingent on implementation of proposed changes.

October is a key decision point for current participants as it is the deadline to notify the program if a participant intends to exit before the program becomes binding. Many issues remain to be resolved in the WRAP design which is illustrated by the number of Concepts submitted in December. For very practical reasons, many Concepts were not prioritized for the 2025 workplan, including how a participant operates in the Operations program when it has load in both regions of the program. Bonneville believes participants need clarity on how WRAP will work with DAMs to provide the Resource Adequacy services that the program was designed to provide. The design was based on a bi-lateral construct and must be adjusted to work with organized markets that will dispatch resources to meet all load. In addition, participants also need a clear understanding of what the Operations program looks like when a participant has loads and generation in both regions. This needs to be addressed by October for example by clarifying dual region operations, or by revising the program so that all entities operate in a single region. The October deadline (for the 2-year exit provision) will be the point participants are evaluating financial risks for Winter 2027/2028. It is important that WRAP has addressed or mapped a path forward on the key issues at that decision point to give participants confidence that those future risks can be mitigated, while also recognizing much more can be addressed and resolved in the two-year period before the first binding season starts.