This timeline appropriately balances the issues prioritized by the PRC into manageable workstreams.

NorthWestern appreciates the PRC’s, WPP’s, and RAPC’s thoughtful prioritization of the 2025 CRFs in the PRC’s 2026 DRAFT Workplan. In regard to NorthWestern and Renewable Northwest’s joint 2025-CRF-9/10, NorthWestern requests that the PRC clarify the “Workgroup (White paper)” stream, occurring in August/September 2026, to specifically indicate the following: “2025-CRF-9/10 concept sponsors and any additional interested parties, known as the Regional Transmission Workgroup, will meet as necessary during the months of August and September 2026, along with assigned WPP and SPP personnel, to draft preliminary indicative policy regarding the treatment of new regional transmission in the program. Additionally, the Workgroup will work with SPP and WPP staff to define and plan modeling work, possibly within the 2026 Advanced Assessment LOLE modeling (for the S28 & W28-29 seasons), to quantify the potential of: 1) NPC Project Diversity Transfers & FS PRM Decremental Effect 2) NPC Project as a Qualifying Resource with defined Qualifying Capacity Contribution (QCC) values” These two additional NPC Project scenarios would be in addition to the study work outlined in the S28 & W28-29 Study Scope Document. The Summer 2028 LOLE Studies should be completed by 10/31/26 and the Winter 28-29 LOLE Studies should be completed by 3/31/27. NorthWestern requests that SPP provide the Regional Transmission Workgroup with the NPC Project S28 and W28-29 scenario LOLE modeling results as soon as the results become available. The modeling results would be valuable to the Regional Transmission Workgroup in assessing the potential value that regional transmission projects could provide to WRAP participants. The Regional Transmission Workgroup and any additional interested parties would convene in April 2027 to form the Regional Transmission Task Force. This Regional Transmission Task Force would discuss the results of SPP’s NPC Project LOLE modeling and further develop the 2025-CRF-9/10 concepts into a formal Proposal during the period April 2027 through October 2027.

Renewable Northwest (“RNW”) appreciates the opportunity to comment on the Draft Workplan, specifically regarding the approach of the draft Task Force Schedule toward the combined RNW-Interwest Energy Alliance-GridLab-Northwestern Energy (“NWE”) 2025-CRF-9/10 addressing interregional transmission. RNW was pleased that 2025-CRF-9/10 received the second-highest prioritization at the January 28, 2026 Program Review Committee (“PRC”) meeting. This prioritization appears to reflect a broad, cross-sector consensus that relieving transmission constraints and improving interregional connectivity will support regional adequacy and offer solutions to problems facing the western electricity grid. The draft Task Force Schedule attempts to balance that high priority with the need to address certain program changes for WRAP participants before the March 31, 2027 Forward Showing (“FS”) Deadline. Accordingly, rather than standing up a full interregional transmission Task Force in 2026, the Task Force Schedule contemplates developing a white paper on the topic in Q3 2026 then convening a Task Force in Q2 2027. Regarding the white paper, RNW supports the comments of NWE. Specifically, RNW requests that the process of developing the white paper be open and, at a minimum, include representatives from the concept sponsors. RNW also requests that white paper development include modeling to assess both PRM and QCC methods for crediting the value of transmission for resource adequacy. RNW understands that Grid United, the developer of the interregional North Plains Connector transmission line, has offered the use of its in-house ELCC software, SERVM, to support this modeling effort. RNW encourages WPP to work with Grid United on appropriate modeling to support eventual program changes. Regarding the Task Force, RNW requests that the final Workplan explicitly reflect the flexibility to accelerate the start date ahead of April 2027 if possible. RNW appreciates that the April 2027 date immediately follows the March 31, 2027 FS Deadline that is driving the accelerated time frame for some other Task Forces, and that the approach currently reflected in the draft Workplan allows Task Forces with time-sensitive work before the FS Deadline to go first in time while still making progress on interregional transmission. Including language acknowledging the possible acceleration of the interregional transmission Task Force would similarly reflect the high prioritization of this Task Force’s work. Accelerating the Task Force may also be appropriate if the contemplated white paper offers a clear path forward on interregional transmission.

Grid United appreciates the extensive work reflected in the Draft 2026 Workplan and commends the PRC for maintaining flexibility ahead of the first binding season. We recognize that interregional transmission concepts, including 2025 CRF 09/10 REGIONAL TX (FOR CAPACITY), were initially ranked as the second highest priority during the PRC prioritization exercise on January 28, 2026. We further acknowledge that, through subsequent discussions, these concepts were deprioritized relative to efforts viewed as having more “immediately deliverable outcomes” prior to the first binding Forward Showing. While Grid United understands and respects the need to focus on near term binding readiness, we believe that the interregional transmission workstream is uniquely positioned to advance efficiently and with relatively modest incremental burden on WPP and SPP staff. Grid United has existing technical expertise, prior stakeholder engagement, and licensed modeling capabilities using SERVM, the same production cost and reliability modeling platform currently relied upon by SPP and WRAP. Leveraging this foundation, Grid United believes that meaningful progress on this concept can be achieved through a short or medium level of effort rather than a Long six month Task Force cycle. With respect to the August–September workgroup contemplated for development of a white paper related to 2025 CRF 09/10, Grid United respectfully seeks clarity regarding the intended outcome of this process. Grid United stands ready to contribute staff time and analytical resources to support a structured, transparent, and technically grounded effort that results in a clearly articulated preliminary policy proposal supported by modeling results. In our view, a focused two month white paper effort has the potential to substantially narrow outstanding policy questions and reduce the scope of subsequent Task Force work. Accordingly, Grid United encourages the PRC to view the white paper process as an opportunity to materially reduce the remaining time required to complete this workstream. Successful completion should enable the PRC to reconsider the current “Long” time score assigned to 2025 CRF 09/10 and potentially advance the full Task Force effort on an accelerated schedule more commensurate with its original prioritization and broad stakeholder interest. Prioritizing this effort would provide needed policy clarity for interregional transmission investments such as North Plains Connector that have the potential to deliver material capacity value to the WRAP, thereby reducing uncertainty and encouraging development of additional projects that benefit WRAP participants. This workstream should be treated as a priority given the magnitude of potential savings for participants and their ratepayers. Preliminary Grid United analysis indicates that the North Plains Connector alone could yield on the order of 1,500 MW (1,500,000 kW) of capacity value to the WRAP, equivalent to approximately $138 million per year when applying the 2022 WRAP CONE of $91.81 per kW‑year. These estimates are conservative, as they rely on an outdated CONE value and do not capture the growing diversity of the eastern and western grids.

AWEC finds that the Task Force Schedule is appropriate and in particular supports inclusion of concepts AWS/PAC - 14/19 (Data Center/Large Loads) in the 2026 Draft Workplan beginning July 2026. Given the growth of large loads in utility service territories who are participating or plan to participate in WRAP, addressing the appropriate treatment of these large loads is both critical and timely. WRAP participants are making decisions today on resources necessary to meet capacity requirements, and any further delay in addressing the appropriate treatment of non-conforming loads only risks potential over-procurement of resources to the detriment of ultimate ratepayers who will be responsible for these costs.

No response submitted.

APS appreciates the discretion and flexibility exercised by the PRC and WPP in developing the 2026 Workplan Schedule III. In particular, APS found the sequencing reflected in Schedule III to be responsive to participant feedback provided through RAPC discussions, especially with respect to prioritizing concepts that support readiness for the first binding Forward Showing. APS supports the approach of limiting the schedule to two concurrent PRC workstreams, which appropriately balances progress on critical policy issues with stakeholder and WPP staff bandwidth constraints. The incorporation of buffers and alternative development paths (i.e. scoped white papers and non-task-force proposals) is a pragmatic recognition of implementation risk and uncertainty. Overall, Schedule III reflects a thoughtful integration of prioritization, level-of-effort realities, and participant needs.

No response submitted.