Idaho Power Company supports the proposed revisions to the WRAP Deficiency Charge framework.

The proposal improves the alignment between annual resource adequacy obligations and the calculation of deficiency charges by reducing outcomes driven by seasonal timing rather than the magnitude of a participant's deficiency. As described by the proposal, the current framework can produce different charge and revenue distribution outcomes depending on whether a participant's maximum deficiency occurs in Summer or Winter. The proposed changes provide a more consistent and equitable approach by better aligning charges with a participant's annual deficiency position.

Idaho Power also supports the proposed modifications to revenue distributions. The current construct can direct a disproportionate share of annual deficiency charge revenues based on seasonal sequencing. The proposed approach more appropriately reflects annual resource adequacy performance and improves the consistency and transparency of settlement outcomes.

In addition, the proposal should simplify administration during the Transition Period by reducing complications associated with calculating annual obligations and deficiency charges across multiple showing periods. Overall, Idaho Power believes the proposal enhances transparency, predictability, and fairness while preserving the incentives necessary to support WRAP's resource adequacy objectives. Idaho Power therefore supports approval of 2026-NTFP-08 as proposed.

SRP generally supports the proposed approach of separating Monthly and Annual Deficiency Charge calculation. However, SRP recommends using a pro rata approach for the annual charge when a Participants has deficiencies in both Summer and Winter.