Tacoma Power appreciates the careful and deliberate work of the Task Force Members with the support from the Western Power Pool and the Southwest Power Pool. This Task Force carefully discussed and balanced the risks and benefits of multiple options to help the WRAP PRMs contribute to the long-term success of WRAP and its individual members. The proposal represents a valuable compromise with the consensus of most Task Force members, representing a majority of WRAP participants. And forums exist to continue discussion and consideration on issues where the Task Force consensus is not unanimous.
Tacoma Power supports the suggestions of Seattle City Light to address the treatment of June within the proposal. The current treatment of June risks impacting other participants, including Tacoma Power, in the same way Seattle City Light describes, and Tacoma Power supports Seattle’s description of a disconnect between modeled requirements and actual system conditions for that month.
Seattle City Light proposes multiple options to mitigate this problem for June, including modification to the non-peak month status of June and establishment of a shoulder-month exception framework. Tacoma Power considers these options to be valuable enough to warrant consideration by the Task Force and WRAP stakeholders. At the same time, the current Task Force proposal represents a valuable compromise that should move forward expeditiously for the benefit of all WRAP participants while discussions on updating June PRM treatment continue.
Tacoma Power supports additional Task Force discussion to consider whether any of Seattle City Light’s alternatives can be incorporated into the current proposal under its existing timeline, and whether others can be expedited for continued discussion in a subsequent proposal.
Idaho Power would like to thank the PRM Task Force for the extensive work, collaboration, and analysis that went into developing this proposal. Idaho Power understands that this proposal is the result of months of thoughtful discussion, modeling effort, and coordination among participants, WPP and SPP. We also acknowledge the complexity involved in reevaluating the process for setting PRMs. With varying load shapes, resource portfolios, and levels of exposure to PRM volatility amongst participants, there is no single “one‑size‑fits‑all” solution. This proposal’s effort to reconcile these differences into a unified, program‑wide approach is commendable. Idaho Power is supportive of the majority of the concepts put forward by the Task Force, and offers suggestions on a few areas of remaining concern, including the five- and ten-year FSPRMs.
Idaho Power is supportive of the majority of the concepts presented in this proposal including:
- Adjusting the timing of the LOLE studies to allow earlier disclosure of binding FSPRMs;
- Modifying the duration of the binding Winter Season;
- Changes to the LOLE study, including the shifting of LOLE risk to Non-Peak Months, limiting historical weather data to 40 years, and aligning the LOLE study treatment of contingency reserves with RSG requirements; and
- Implementing a Seasonal Peak Load approach to the Summer Season for the months of July and August
Idaho Power is in favor of setting binding FSPRMs earlier than the current process allows for, which sets binding FSPRMs 9 months ahead of the FS deadline. The company believes earlier setting of the binding FSPRMS will benefit long-term viability of the program. Specifically, by setting the binding FSPRMs earlier, participants will have improved visibility into future obligations and more time to secure needed resources and mitigate compliance risk.
The company is also encouraged by the PRM Task Force’s proposal to adjust LOLE risk allocated across the months of the season, while maintaining the 1‑in‑10 reliability standard over the entire season. Idaho Power believes this change will more accurately align capacity requirements with loss of load risk, i.e., capacity requirements will be lower in Non-Peak Months when loss of load is less likely to occur.
While Idaho Power is largely supportive of the proposal as written, it offers the following suggestions to the PRM Task Force for consideration.
Idaho Power recognizes there is a tradeoff in setting the binding FSPRMs 5 years ahead of the FS deadline, which is less accuracy in load and resource assumptions used to set the binding FSPRMs and potentially increased FSPRM volatility. Specifically, lower accuracy in load and resource assumptions looking ahead five-plus years could lead to relatively higher FSPRMs, compared to the PRMs that might result from using closer-in-time, more accurate load and resource information. As mentioned above, Idaho Power recognizes the benefits of locking in the FSPRMs further in advance, and is supportive of the concept, but is concerned that the uncertainty that may still exist in loads and resources five-plus years into the future could lead to FSPRMs that are unrealistic.
There may be a few alternative ways to mitigate this issue. One potential option could be to allow greater time between participants receiving the draft FSPRM results and the deadline for study completion to allow a more rigorous process of reviewing input data and the draft FSPRM results, as well as allowing time to conduct any updated modeling.
Another option could be for the FSPRM modeling to consider a range of scenarios: high and low load; and the associated resources with each; with the ultimate PRMs being within those bookend cases; or for the FSPRMs to be set at a point that is less than five years in advance (i.e., potentially three years could be an option).
Another option could be to allow for additional review or participant comment after the final FSPRMs are determined but before they go to the WPP Board for approval. The Board should have the flexibility to consider the FSPRMs and approve them, not approve them, or defer approval until after additional modeling is completed, even if the ultimate binding PRM is set at a point that is less than 5 years advance. Idaho Power is not suggesting any form of restudy after the binding FSPRMs have been set.
Idaho Power welcomes the Task Force’s thoughts and creativity on this issue and the options to address it, and how the binding FSPRMs with further advance notice might be implemented in terms of setting values that are realistic and reasonable.
The company also questions whether the 10-year advisory FSPRMs are necessary. Given the evolving energy landscape, participants’ load and resource assumptions used to determine the 10-year advisory FSPRMs will likely be stale and inaccurate, and therefore the results invalid. Additionally, relieving the Program Operator of conducting a 10-year advisory study may create additional bandwidth to conduct a more comprehensive review of draft 5-year FSPRM results, and any updated modeling needed, as mentioned above.
Finally, Idaho Power understands the PRM Task Force’s need to limit scope and avoid scope creep, whereby it proposed to defer changes to P50 Peak Load Forecast methodology and QCC/ELCC design to future task forces. However, the company would like to reiterate the importance of establishing the PRM Task Force proposed changes as guardrails to the upcoming Load Forecasting and QCC/ELCC Task Forces so that those efforts do not inadvertently undermine gains achieved in this task force or overlook interactions of these components and the implications.
Overall, this proposal represents a thoughtful evolution of WRAP’s PRM framework. It takes meaningful steps toward improving predictability, reducing volatility, and better aligning monthly and seasonal requirements with actual reliability risk. Again, Idaho Power appreciates the balanced approach taken to address diverse participant needs.
Thank you for the opportunity to review and comment on this proposal.
Seattle appreciates the significant effort of the PRM Task Force to improve planning certainty and reduce month-to-month volatility in WRAP capacity requirements. These are important objectives as the program transitions toward a binding framework, and Seattle supports continued work to improve transparency, predictability, and proportionality in the PRM methodology.
However, Seattle cannot support the proposal as currently drafted due to the continued treatment of June within the LOLE methodology and resulting monthly PRM outcomes. While June is identified as a non-peak month, the proposal continues to produce a comparatively high PRM that does not align with observed system risk, hydro conditions, or regional load patterns for that period. From Seattle’s perspective, this indicates that the proposal has not sufficiently resolved the core issues of shoulder month PRM misalignment.
Under current and proposed outcomes, June PRM requirements have potential to push participant capacity obligations hundreds of megawatts above historical June peak levels. This creates a material disconnect between modeled requirements and actual system conditions and introduces procurement and operations challenges that are not commensurate with reliability risk. Maintaining a high PRM in June places a disproportionate obligation on participants and shifts capacity requirements into a month where regional reliability risk is comparatively lower. This outcome runs counter to the stated objectives of improving stability and aligning monthly requirements with actual risk.
Seattle previously submitted a WRAP Change Request proposing a targeted shoulder-month PRM exception mechanism. As written, that proposal contemplated a limited exception when a monthly PRM would require capacity levels that materially exceed the participants historical peak for that month. In some cases, by several hundred megawatts, and where such an outcome is not supported by underlying reliability conditions. That concept remains directly relevant to the concerns raised here and may provide a practical off-ramp if monthly modeling outcomes continue to produce disproportionate requirements in June or other non-peak months.
Seattle supports the broader goals of improving timing and reducing volatility but believes the proposal requires further refinement before adoption. Specifically, Seattle recommends that the Task Force reconsider the treatment of June within the LOLE risk allocation framework and ensure that June PRM levels are proportionate to actual reliability risk.
Absent further adjustment resulting in a lower June PRM, or the inclusion of a clear and workable shoulder-month exception framework, Seattle cannot support the proposal in its current form. Addressing this issue is necessary to ensure the methodology produces monthly requirements that are aligned with reliability risk, operationally reasonable, and workable for participants across both regions.