Tacoma Power appreciates the careful work of the Task Force to develop a workable transition rollout and supports the Implementation Plan and Feasibility section.
No response submitted.
APS values the clear transition roadmap and the candid discussion of risks associated with earlier metric setting. We believe the Implementation Plan would be strengthened by explicitly addressing how material participation changes after binding PRM approval would be evaluated and managed. Clear checkpoints or adjustment pathways would help ensure that reliability objectives remain intact throughout the Forward Showing horizon.
SRP appreciates the WPP and Task Force providing clarification on whether there is a path to change the FSPRM after it is established. Additionally, the proposal acknowledges several key risks, including the potential for conditions to change after the FSPRM is set, meaning the LOLE study could include participants that later enter/withdraw and materially change the participant mix before a binding season. SRP also understands that the Task Force did not reach consensus on a solution for such circumstances, however the PRC and RAPC would not be precluded from considering circumstances and making a decision to address them through WRAP’s governance process.
SRP further appreciates the WPP for sharing that this proposal to extend the FSPRM timeline is implemented through BPMs and not the Tariff. Therefore, if there should be a situation where circumstances materially change after FSPRM is set, participants will have a path to submit an NTFP to change the BPMs to allow an out-of-cycle FSPRM update. SRP appreciates this flexibility and recommends the proposal document this path.
Seattle appreciates the phased implementation plan and the effort to transition thoughtfully to the proposed methodology. The staged rollout provides participants with time to adjust planning processes and understand the new framework.
However, Seattle notes that implementing earlier FSPRM metrics and revised methodology without addressing the continued elevation of June PRMs may embed the very volatility and misalignment the proposal seeks to correct. If June continues to reflect a high PRM, advancing the timeline and locking in metrics further in advance could increase planning risk for participants.
Seattle recommends that the Task Force consider additional review of shoulder month outcomes particularly June, before full implementation of the revised methodology. Ensuring that monthly PRM’s are proportionate to risk will improve the effectiveness of the implementation plan and increase participant confidence in the resulting metrics.