Black Hills Colorado Electric appreciates the opportunity to comment on EP-06. BHCE supports the proposed revisions related to the Rockies Subregion Forward Showing deadline and associated timeline adjustments.

As WPP notes in the proposal, the creation of the Rockies Subregion presented a unique timing challenge because there were no Rockies participants at the time the standard WRAP deadlines occurred and therefore no established FSPRMs for the subregion. Since then, significant progress has been made to support implementation of the Rockies Subregion. In particular, stakeholders have worked collaboratively to develop solutions that recognize the unique circumstances associated with bringing a new subregion into WRAP.

BHCE appreciates the flexibility shown by WPP staff and WRAP stakeholders throughout this process. The willingness to work through stakeholder concerns and develop practical transition solutions has helped create a workable path forward for potential Rockies participants.

While BHCE previously raised concerns regarding the waiver request filed earlier this year, the stakeholder process has since produced a more complete solution that includes both revised timelines and transition provisions for Rockies participants. We believe the proposal provides a reasonable path forward and supports participation in the Winter 2027-2028 WRAP Binding Season for the subregion.

BHCE also supports the proposed timeline modifications, which maintain a seven-month period between FSPRM approval and the Forward Showing deadline while preserving the existing 60-day cure period for participants. These adjustments appropriately balance the need to onboard the Rockies Subregion with the broader WRAP implementation schedule.

As BHCE continues evaluating its resource adequacy requirements and market participation options, the metrics, information, timelines, and transition framework reflected in this proposal will be helpful in informing those evaluations.

For these reasons, BHCE supports EP-06 and appreciates the efforts of WPP staff and stakeholders to develop a practical and collaborative solution for the Rockies Subregion.

Respectfully,

Kerri Schlachter

Black Hills Energy

Idaho Power supports the proposed tariff and BPM changes establishing a process to develop and implement Forward Showing Planning Reserve Margins (FSPRMs) for the new Rockies Subregion. The proposal addresses a practical implementation issue created by the addition of new Colorado participants after the standard WRAP timelines for establishing subregional metrics had passed.

Idaho Power agrees that WRAP should provide a workable path for onboarding new participants and subregions while maintaining the integrity of the resource adequacy framework. Given that there were no Rockies participants when the original deadlines occurred and that FERC denied WPP's waiver request, the proposed tariff revisions represent a reasonable approach to establishing the necessary metrics and enabling participation in the program.

Idaho Power appreciates the efforts of WPP, stakeholders, and SPP to develop the required FSPRMs and supports approval of 2026-EP-06 as proposed.

Powerex supports 2026-EP-06 and the establishment of the Rockies Subregion. The WRAP is a regional program whose value grows with its footprint, and the proposed changes enable that growth without departing from the program's established framework. The Rockies-specific timelines are consistent with the treatment other Participants receive: the seven-month interval between FSPRM approval and the FS Deadline and the full 60-day Cure Period are preserved, with the necessary compression absorbed in WPP review periods rather than Participant obligations. Taken together, the proposal gives entities in the Rockies a reasonable series of dates to join the WRAP and complete the Forward Showing process for the Winter 2027-2028 Binding Season, and Powerex encourages the Board to approve it.