Tacoma Power supports the updates currently contained within the proposal that represent a compromise after extensive Task Force discussion balancing risks and benefits. Tacoma Power also supports the comments that have been submitted by Seattle City Light addressing high PRMs for June. The current schedule could accommodate Task Force discussion of whether any aspects of Seattle City Light’s suggestions could be incorporated into the current proposal and whether any are more appropriate for consideration in a subsequent process.

No response submitted.

APS appreciates the Task Force’s efforts to stabilize month‑to‑month PRM outcomes while maintaining the 1‑in‑10 LOLE reliability benchmark. APS is comfortable with the proposed methodological updates, including Non‑Peak Month LOLE floors, use of a rolling 40‑year weather dataset, and continued alignment with evolving contingency‑reserve standards. Specifically, on the Non-Peak LOLE floors, APS believes it is appropriate to continue maintaining those within the Forward Showing Study Scope to allow for refinement if the proposed values have unanticipated impacts on the peak months. APS notes, however, that the effectiveness of all these enhancements is dependent on reasonable alignment between modeled assumptions and actual participation levels over time.

SRP is concerned that prescriptively assigning higher allowable risk in the shoulder months will result in higher capacity requirements in the peak months of each season. SRP finds that the high level of assigned per-day risk for shoulder months with reduced days in the binding season creates a condition where shoulder month obligations will be significantly reduced at the expense of peak months. By way of example, if the last 11 days in November are indeed a reliability risk, the application of allowed per-day risk at a higher level than peak months will likely obscure this reliability concern behind lower-than-justified capacity requirements. While SRP would otherwise be supportive of the shortened Winter Binding Season, SRP does not believe that the redefined season duration is consistent with the prescribed risk allocation to November. Rather than a prescriptive assignment of risk to each month, SRP would advocate for the WRAP Program Operator to retain existing professional autonomy to iteratively allocate risk based on initial simulations in a way that balances Participant capacity requirements across the season. The WRAP Program Operator’s ability to balance monthly obligations within each season would be stronger with seasonal modeling (including seasonal capacity value for resources), but SRP would still advocate for removing prescriptive monthly risk assignment from the proposal.

Seattle appreciates the Task Force’s work to address monthly PRM volatility and better distribute LOLE risk across the months. The objective of improving stability and predictability in monthly requirements is important as WRAP transitions into a binding program. However, Seattle does not support the current treatment of June under the proposal. While June is identified as a non-peak month, it continues to carry a comparatively high PRM that does not appear proportionate to observed system risk or regional operating conditions. From Seattle’s perspective, this indicates that the proposed redistribution of LOLE risk has not sufficiently corrected shoulder month outcomes. Maintaining a high PRM in June creates planning and procurement challenges for participants and risks shifting capacity obligations into periods where reliability risk is comparatively lower. This outcome undermines the proposal’s stated objective of aligning monthly requirements with modeled risk and reducing volatility. Seattle recommends that the Task Force: • Re-examine the minimum LOLE risk allocation assigned to June • Provide additional transparency into how risk is being distributed across peak and non-peak months • Conduct sensitivity analysis on June PRM outcomes using alternate risk allocation approaches. • Consider whether June should carry a lower minimum threshold consistent with classification as a non-peak month. Seattle supports efforts to improve stability but believes the methodology requires further refinement to ensure June requirements are proportionate to actual system reliability risk.