01. Please provide any comments on the proposal to adjust the timing of the FSPRM calculation (LOLE Study).

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.

02. Please provide any comments on modifying the duration of the Winter Binding Season.

APS supports the proposal to shorten the Winter Binding Season to November 20 through February 28/29, as well as the formal identification of Peak and Non‑Peak Months. These changes are supported by historical LOLE results and better align capacity obligations with periods of demonstrated reliability risk. APS agrees that periodic review will be important as system conditions, weather patterns, and load characteristics evolve.

03. Please provide any comment on the proposed updates to the methodology of the LOLE Study.

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.

04. Please provide any comment on the Implementation Plan and Feasibility section of the proposal including Risks, Schedule, and Impacts.

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.

05. Please provide any comments on the redlines to WRAP Tariff.

No response submitted.

06. Please provide any comments on the redlines to BPM 101 – Advance Assessment.

No response submitted.

07. Please provide any comments on the redlines to BPM 102 – Forward Showing Reliability Metrics.

No response submitted.

08. Please provide any comments on the redlines to BPM 103 – Participant Forward Showing Capacity Requirements.

No response submitted.

09. Please provide any comments on the redlines to BPM 104 – Capacity Critical Hours.

No response submitted.

10. Please provide any comments on the redlines to BPM 105 – Qualifying Resources.

No response submitted.

11. Please provide any comments on the redlines to BPM 108 – Forward Showing Submittal Process.

No response submitted.

12. Please provide any comments on the redlines to BPM 109 – Forward Showing Transition Period.

No response submitted.

13. Please provide any comments on the redlines to BPM 401 – New Participant Onboarding.

No response submitted.

General Comment

APS appreciates the substantial work undertaken by the PRM Task Force and supports many individual elements of the proposal. However, given the potential reliability impacts associated with material participation changes occurring after binding PRMs are set, APS is unable to support the proposal overall as drafted. APS looks forward to continued collaboration with participants and the Task Force on refinements that address this concern while advancing the shared goal of a reliable and predictable resource adequacy framework.