Tacoma Power appreciates the work of the Planning Reserve Margin Task Force and the opportunity to submit these comments. Tacoma Power also supports the proposal to establish Forward Showing Planning Reserve Margin values five years in advance of the applicable forward showing season. WRAP should enable participants to supplement their long-term planning with the regional diversity benefits of the program. This proposed timing will enable participants facing a deficiency to plan with a broader range of options to meet the deficiency rather than being forced to limit those options because of short deadlines. The task force spent a meaningful amount of time considering and balancing the benefits and risks of various options to modify PRM calculations and timelines. This proposal on the timing of the FSPRM calculation, as well as other aspects of the Task Force proposal, represents a valuable compromise. Additional discussions should continue to consider other options to refine the FSPRM process, but this proposal should move forward expeditiously as a valuable step that represents a consensus of most WRAP participants.

No response submitted.

Arizona Public Service Company (APS) appreciates the Task Force’s efforts to provide earlier visibility into Forward Showing Planning Reserve Margin (FSPRM) requirements and recognizes the potential planning benefits of additional lead time. However, APS remains concerned with the misalignment between the proposed timing for approval of binding FSPRMs—five (5) years in advance of the Forward Showing Deadline—and the WRAP withdrawal‑notification framework. As acknowledged in the proposal, this timing creates the possibility that Participants included in the LOLE Study and binding PRM determination may subsequently withdraw prior to the applicable Binding Season. Under certain scenarios, this could challenge the WRAP’s ability to reliably meet the 1‑in‑10 LOLE standard. Maintaining this standard is a foundational program objective for APS. Accordingly, while APS supports the objective of earlier PRM visibility, APS is unable to support the proposal as drafted absent additional triggers to manage the reliability expectations associated with material changes in participation. APS would welcome continued dialogue on potential safeguards, including clearly defined triggers for reassessment, maintaining alignment of timing for approval of binding FSPRMs and program withdrawal notification, or other transparent processes that ensure binding PRMs remain aligned with actual participation at delivery.

Salt River Project (SRP) appreciates the time invested by Task Force participants on this proposal and the intent to set the FSPRM further in advance to improve planning certainty. SRP also appreciates that the Task Force explored tradeoffs between planning certainty and reliability risk, and we recognize that any proposed change must balance these two considerations. SRP also recognizes that setting a binding FSPRM five (5) or more years ahead may create misalignments with other key program drivers that are determined closer to the binding season, such as ELCC results. Mismatches in these key determinants of program requirements and QCC could lead to the program being more or less reliable than its intended target (0.1 LOLE per season). While Participants may find this tradeoff acceptable, SRP would advocate for steps that could reduce some of the misalignment, including a potential “no greater than” treatment that would allow the Program Operator to lower the PRM requirement within the 5-year window if additional Participants join the program or if a Participant adds transmission that improves regional reliability. While acknowledging that the proposed change provides an incremental improvement in certainty for Participant planning purposes, SRP is not convinced that full actionable planning certainty will result from locking in the PRM 5 years in advance in isolation. Future loads will remain significantly uncertain on a 5-year ahead basis and ELCC values will continue to be calculated 2 years in advance. Exploration of these three planning elements in concert is needed to achieve the desired level of planning certainty.

Seattle supports improving planning certainty through earlier visibility into Forward Showing Planning Reserve Margin (FSPRM) values. However, advancing FSPRM approval five years ahead of the binding season does not solve Seattle’s primary concern with the proposal, which is the continued misalignment between modeled monthly PRMs and observed reliability risk, particularly in June. Establishing metrics further in advance increases the importance of ensuring that monthly PRM outcomes are proportionate to actual system risk. If Monthly values remain overstated in shoulder months, advancing the timeline may lock in requirements that are not reflective of real-world reliability needs and may be difficult for participants to adjust to once set. Seattle recommends that improvements to timing be paired with additional refinement of the LOLE methodology so that earlier metrices reflect a more accurate distribution of risk across months. Without such refinement, earlier FSPRMs may provide planning certainty but still embed structural issues in monthly PRM outcomes.