SRP encourages BPA and the WPP to facilitate a collaborative task force discussion among WRAP participants before a permanent program change is adopted, to help ensure participant alignment.

SRP recognizes long-term firm transmission can be exceptionally difficult to identify and procure, which is why firm transmission is a critical element of the WRAP Forward Showing.  SRP acknowledges that Forward Showing requirements for firm transmission may create an artificial undersupply of qualifying transmission rights relative to the aggressive procurement that could result from unnecessarily severe firm transmission requirements.

SRP understands that transmission from resources to load is a critical element of resource adequacy, and that planning entities often account for load forecast error in transmission procurement.  SRP believes that many entities use P90 or otherwise “high” load forecasts for internal transmission planning, a risk-averse path to mitigate the exceptional challenge in procuring new transmission, including in the near-term.  Recognizing that WRAP only includes one load forecast as part of the Forward Showing, the current language (P50 + PRM) may be a reasonable treatment to yield similar risk-averse treatment.

The current 75% treatment is a clear acknowledgment that 100% transmission coverage is not required by the time of Forward Showing submittal.  However, SRP believes that collaborative discussions may help ensure that a reduction in the firm transmission requirements appropriately reflects a consensus view on how transmission supports resource adequacy.  Prior to broad changes, SRP would support discussion of tradeoffs accepted with firm transmission requirement reductions for WRAP participants. 

SRP also recommends consideration be given to timing and prioritization of ongoing efforts within WRAP. From SRP’s perspective, it may be beneficial to focus first on getting foundational WRAP processes in place before adopting permanent changes that materially revise firm transmission demonstration requirements.

Idaho Power appreciates BPA's work in describing the issue presented in this NTFP, as well as, providing redlines to the applicable BPMs and tariff. The proposal elicited the following questions for Idaho Power.   

Why propose to remove the PRM from the Forward Showing transmission requirement calculation rather than simply lowering the overall transmission requirement percentage from 75% to a lower value? Wouldn't adjusting the percentage provide a more flexible approach while still maintaining a direct link between transmission and the total capacity requirement? Additionally, has any analysis been done to review the impact to reliability, resource adequacy, and the Western Resource Adequacy Program’s goals if the transmission requirement is reduced? 

Thank you for the opportunity to provide comments. 

Arizona Public Service Co. (APS) appreciates the effort that Bonneville Power Administration (BPA) invested in developing this proposal.  APS would prefer to see any change to this component of the WRAP be the result of collaborative participant discussions as opposed to a Non-Task Force Proposal because this is a challenging topic that should be thought about and discussed by all participants.

APS does not believe that the change proposed will enhance resource adequacy in the region, which is the primary objective of the WRAP, therefore APS is unable to support this proposal:

• Ensuring regional resource adequacy requires development of both resources and transmission. Similar to common generation planning practices, transmission development is needed to ensure reliable operations.
• The current transmission requirement of 75% of FS Capacity Requirement reflects a compromise among WRAP participants with many seeking to expand the transmission requirement to 100% of FS Capacity Requirement.  Ensuring 100% deliverability is common among RA programs and appropriate as transmission is not fungible between resources except as similarly located.
• Transition to an approach that excludes PRM in setting a transmission requirement is inconsistent with the intention of a PRM.  The load value used in the Forward Showing is only a P50 load – meaning the load has a 50% chance of being higher or lower than the projected load value.  Load of closer to a P100 is included in the PRM and should not be separated from the transmission requirement.   
• The WRAP deliverability requirement is critical to ensuring transmission continues to develop as Day-ahead markets develop. Over the next few years, most of the Western entities are moving to one of two Day-Ahead LMP market offerings, neither of which contains a centralized transmission planning component. LMP markets will make transmission less economic to develop except as required by RA program requirements.  Weakening this component of the program weakens future transmission development.

In summary, APS views the subject of this proposal as one that would benefit from a more collaborative participant discussion beyond that available via the NTFP process and encourages BPA to consider other avenues for exploring changes to this component of the WRAP.