Tacoma Power appreciates the opportunity to comment on this draft workplan, and the work of WRAP and WRAP Participants to evaluate priorities in advance of the Winter 2026-27 Binding Season. Considering that approaching deadline, this draft workplan appropriately prioritizes the most crucial issues. The task forces that have been operating throughout 2025 and 2026 have made meaningful progress and built a valuable knowledge base. We hope the continuing workstreams described in the draft workplan can build on that progress and knowledge base. We recognize that not every issue submitted to the PRC was able to be included in this Draft Workplan, and we hope that issues that were not prioritized here can receive continued attention later. Specifically, Tacoma Power agrees that participants would gain significant value from a more transparent quantification of WRAP benefits and capacity savings.

RNW appreciates that WRAP’s governance process channels the change process through the PRC, the body reflecting broad, sector-based representation.  In approving the WRAP Tariff, FERC specifically found that the “governance structure” – including the PRC, which comprises representatives of interested sectors as well as participants – “strikes a reasonable balance between allowing Participants to make decisions and enabling interested non-Participant stakeholders to observe and comment on those decisions.”  Nw. Power Pool, 182 FERC ¶ 61,063, 61,519 (2023).  FERC stressed the importance of adequate “openness and inclusiveness” in the governance process.  Id. 

Given this, RNW also appreciates RAPC’s attempt to problem-solve and identify a path forward that reflects the priority afforded to interregional transmission by the PRC while still making progress on Task Forces necessary to allow participants to meet their FS obligations and remain in the program.  However, we note that the draft Task Force Schedule currently reflects an approach developed by RAPC.  In the spirit of WRAP’s FERC-approved governance structure, we encourage WPP and the PRC to consider adopting the clarifications set forth in our comments above and NWE’s comments in order to more fully reflect the interests of both participants and non-participants.

Grid United respectfully submits the following comments on the Draft PRC 2026 Workplan. We appreciate the significant effort undertaken by the PRC, WPP staff, and RAPC to align the Workplan with participant needs as the WRAP prepares for its first binding Forward Showing deadline of March 31, 2027, for Winter 2027–2028. The Draft Workplan reflects a thoughtful balancing of ambition, staff bandwidth, and participant readiness during a critical program transition.

The Alliance of Western Energy Consumers (“AWEC”) is a trade organization whose members include many of the Pacific Northwest’s largest employers and consumers of electricity and natural gas.  AWEC’s members are responsible for providing tens of thousands of highly paid, technical, family-wage jobs across a broad range of industry sectors such as agriculture, aeronautics, air products, metals, pulp and paper, and more.  As such, AWEC’s members provide significant economic benefits to the communities in which they are located.  Many of AWEC’s members’ host utilities are committed to going binding in Winter 2027 or are themselves customers of Bonneville Power Administration who will participate on their behalf.  As such, AWEC’s members are retail consumers who bear the costs and will receive the benefits of WRAP participation.  AWEC supports a robust resource adequacy program to ensure reliability in the Pacific Northwest and beyond, particularly given the evolving energy landscape. AWEC is also a proponent of ensuring that resource procurement, and ultimately cost allocation, are driven by the principle of cost causation and preserving customer choice when doing so will result in efficient rates and reliable service. 

To: WRAP Program Review Committee

From: Committee of State Representatives

Date: April 15, 2026

RE: COSR Comments on the Western Resource Adequacy Program 2026 Draft PRC Workplan

Dear Program Review Committee Members:

Thank you for the opportunity to review the Western Resource Adequacy Program’s (WRAP) 2026 Draft PRC Workplan (1), as developed by the Program Review Committee (PRC), with input from the Resource Adequacy Participants Committee (RAPC) and posted for comment on March 13, 2026. The Committee of State Representatives (COSR) recognizes the significant level of effort and collaboration required to develop this Workplan over the past three months. In accordance with the WRAP’s Business Practice Manual (BPM) 301 – PRC Workplan Development and Approval (2), the COSR and other stakeholders are granted an opportunity to provide comments and recommended design changes to the WRAP, including the annual Workplan. Our comments are as follows: (3)

Following multiple reviews and discussions of the PRC 2026 Workplan, the Committee of State Representatives (COSR) supports the proposed prioritization and sequencing of significant issues that will affect the WRAP. Specifically, a robust resource adequacy framework would benefit from policies that account for the rapid emergence of large, non‑conforming, high‑load‑factor resources across the West (Concepts 14/19). Initiating a Task Force in 2026 will enable participants to more quickly develop an improved understanding of how these large loads may affect resource procurement decisions and load obligations in advance of the March 31, 2027 Forward Showing (FS) deadline. The COSR also welcomes the Workplan’s development of a whitepaper later this year to explore the initial scope and indicative policy direction for Regional Transmission Capacity, prior to the formation of the Task Force and full modeling efforts in 2027 (Concepts 09/10). Assessing regional transmission could promote an improved understanding of potential transfers that would otherwise not exist, potentially lowering planning reserve margins (PRMs) in the WRAP regions by leveraging new interchange import capacity. Similarly, the COSR supports future efforts to examine certain transmission lines for potential inclusion as a qualifying resource with attributed capacity values sufficient for inclusion in a participant’s FS Capacity Requirement.

The COSR further acknowledges the Program Administrator’s efforts, consistent with BPM 301, to account for the time and resource demands placed on WRAP participants and Western Power Pool (WPP) staff in executing the proposed 2026 Concepts, as well as the remaining 2025 Workplan Concepts. The proposed Workplan appropriately leverages multiple short-term implementation pathways outside of traditional workstreams (e.g., Non-Task Force Proposals (NTFP), expedited workstreams, and whitepapers) to advance critical program enhancements ahead of the first Binding Season. The COSR agrees that certain initiatives, including the WRAP E-Tags and Inter-Participant Joint Contract Accreditation Form (JCAFs) proposals, can be addressed on a shorter timeline and ultimately reduce administrative burden for participants. 

Recognizing the amount of work to be completed within a short timeframe, the COSR values continued updates, especially related to the Day-Ahead Market Optimization and Deficiency Deferral efforts. Developing an advanced understanding of these important and complex enhancements will enable the COSR to provide well‑informed comments. The COSR would also appreciate further clarification regarding the procedural impacts of various 2025 and 2026 Workplan Concepts to be completed in 2026 (i.e., which Concepts will require BPM updates and/or tariff changes). Ultimately, the COSR supports the 2026 Workplan’s approach and views it as a pragmatic means of addressing priority issues, given the limited time and resources.

Following a vote at the COSR monthly meeting on March 27, 2027, the Committee endorsed these comments by a majority of the current members. The COSR appreciates the continued efforts of the PRC, the RAPC, and WPP staff to prioritize and implement program enhancements.

Respectfully,

The Committee of State Representatives

Chris Parker
Chair, Committee of State Representatives
Director, Utah Division of Public Utilities
 

Brian Rybarik
Vice Chair, Committee of State Representatives
Chairman, Washington Utilities and Transportation Commission
 

(1.) https://www.westernpowerpool.org/private-media/documents/2026-03-13_Draft_PRC_Workplan.pdf. 

(2.) All WRAP BPMs can be found at: https://www.westernpowerpool.org/resources/wrap_bpms/.

(3.) These comments are not intended to pre-empt, supplant, or otherwise circumvent any state or provincial regulatory processes or determinations. As a standing committee of the WRAP, the COSR exists to provide state and provincial guidance on matters pertaining specifically to the program. Any comments provided by the COSR do not indicate individual member positions on proceedings in their respective states and should not be considered pre-judgment of any kind.

APS supports adoption of the 2026 PRC Workplan as drafted. The Workplan reflects a balanced approach that prioritizes participant readiness for the first binding WRAP Forward Showing while acknowledging practical implementation constraints. APS appreciates the continued collaboration among WPP, PRC, RAPC and other stakeholders and looks forward to productive engagement through the upcoming Task Forces and proposal development efforts.

Bonneville appreciates the opportunity to comment on this workplan, and for all the coordination and effort put in by the WPP, WRAP members, and stakeholders in compiling this workplan.

Bonneville supports this workplan, but does have a few minor comments for consideration:

1. Including all previous revisions in the current draft of the workplan makes for a cluttered read. Bonneville suggests retaining these versions for reference, but only including the latest draft when sending out for comment
2. We would like to recognize the volume of high priority issues brought to the PRC as participants head towards the first binding season and recognize that this plan and the priorities approved in it may not meet every participant’s needs prior to the program going binding.  Participants may need to bring NTFP’s forward to resolve issues that were not prioritized, or for issues that got prioritized later then needed to address issues impacting compliance with the binding program. NTFP consideration should not be delayed because the issue is scheduled to be addressed via a task force later in the PRC workplan. An influx of NFTP’s will have an impact on WPP Staff time, as well as participants and PRC review efforts.