COMMENT FOR 2026 Draft PRC Workplan

Submitted April 15, 2026, 3:22 p.m.





01. Please supply any comments on the draft Task Force Schedule found in Figure 5 (Schedule III)

APS appreciates the discretion and flexibility exercised by the PRC and WPP in developing the 2026 Workplan Schedule III. In particular, APS found the sequencing reflected in Schedule III to be responsive to participant feedback provided through RAPC discussions, especially with respect to prioritizing concepts that support readiness for the first binding Forward Showing. APS supports the approach of limiting the schedule to two concurrent PRC workstreams, which appropriately balances progress on critical policy issues with stakeholder and WPP staff bandwidth constraints. The incorporation of buffers and alternative development paths (i.e. scoped white papers and non-task-force proposals) is a pragmatic recognition of implementation risk and uncertainty. Overall, Schedule III reflects a thoughtful integration of prioritization, level-of-effort realities, and participant needs.

02. Please supply any comments on Concepts that would provide valuable clarification ahead of the March 31st, 2027, Forward Showing Deadline for the first Binding Season of Winter 2027-2028

APS believes the following concepts would provide the most value in advance of the March 31, 2027 Forward Showing deadline for the first binding Season (Winter 2027–2028): • Day-Ahead Market Optimization • Effective Load Carrying Capability (ELCC) approach • Forward Showing Deficiency Deferral Resolution • Participant-to-Participant Joint Capacity Accreditation Forms (JCAFs) APS supports the draft Workplan as presented under Schedule III, which appropriately positions each of these items for completion, clarification or meaningful progress ahead of the Forward Showing deadline. Advancing these concepts on the proposed timeline will materially improve participant certainty and support successful execution of WRAP during the first binding period.

03. Please supply any comments on the Executive Summary

No response submitted.

04. Please supply any comments on Section 1. Background

No response submitted.

05. Please supply any comments on Section 2. PRC Prioritization Exercise

No response submitted.

06. Please supply any comments on Section 3. Detailed Level of Effort Review

No response submitted.

07. Please supply any comments on Section 4. Proposed Schedule and Plan of Action

No response submitted.

08. Please supply any comments on Appendix A - Change Request Form Compilation

No response submitted.

09. Please supply any comments on Appendix B - PRC Minutes Dec. 18th, 2024

No response submitted.

10. Please supply any comments on Appendix C - PRC Minutes Jan. 28th, 2026

No response submitted.

11. Please supply any comments on Appendix D - PRC Minutes Feb. 11th, 2026

No response submitted.

General Comment

APS supports adoption of the 2026 PRC Workplan as drafted. The Workplan reflects a balanced approach that prioritizes participant readiness for the first binding WRAP Forward Showing while acknowledging practical implementation constraints. APS appreciates the continued collaboration among WPP, PRC, RAPC and other stakeholders and looks forward to productive engagement through the upcoming Task Forces and proposal development efforts.

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