Idaho Power supports the proposal to update the WRAP contingency reserve methodology to align with the new contingency reserve requirements adopted by the Western Power Pool Reserve Sharing Group (RSG) following the retirement of BAL-002-WECC-3. Aligning WRAP's resource adequacy framework with the reserve requirements that participants are expected to meet operationally is a reasonable and appropriate policy objective.

While Idaho Power supports incorporating the new contingency reserve standard, we encourage the Program Operator and stakeholders to ensure that the methodology used within WRAP remains closely aligned with the methodology used by the Reserve Sharing Group (RSG). The proposal notes that the RSG contingency reserve requirement is calculated based on the footprint's Most Severe Single Contingency and allocated to Balancing Authorities using a weighted pro rata share of generation and load.

To the extent contingency reserve requirements are translated from a Balancing Authority construct to a Load-Responsible Entity construct within WRAP, Idaho Power believes any differences should be limited to those necessary to reflect the distinct responsibilities of an LRE rather than a BA. The underlying assumptions, allocation principles, and calculation methodology should otherwise remain as consistent as possible with the RSG framework.

Maintaining this alignment will improve transparency, simplify implementation, reduce the potential for unintended discrepancies between operational and resource adequacy requirements, and provide greater confidence that WRAP participants are being assigned reserve obligations that appropriately reflect the reserves required across the broader footprint.

Subject to ensuring this consistency with the RSG methodology, Idaho Power supports adoption of 2026-EP-07.