01. Please supply any comment related to the proposed changes in the Tariff.

No response submitted.

02. Please supply any comment related to the proposed changes in BPM 106.

No response submitted.

03. Please supply any comment related to the proposed changes in BPM 107.

No response submitted.

04. Please supply any comment related to the proposed changes in BPM 108.

No response submitted.

General Comment

Arizona Public Service Co. (APS) appreciates the effort that Bonneville Power Administration (BPA) invested in developing this proposal.  APS would prefer to see any change to this component of the WRAP be the result of collaborative participant discussions as opposed to a Non-Task Force Proposal because this is a challenging topic that should be thought about and discussed by all participants.

APS does not believe that the change proposed will enhance resource adequacy in the region, which is the primary objective of the WRAP, therefore APS is unable to support this proposal:

• Ensuring regional resource adequacy requires development of both resources and transmission. Similar to common generation planning practices, transmission development is needed to ensure reliable operations.
• The current transmission requirement of 75% of FS Capacity Requirement reflects a compromise among WRAP participants with many seeking to expand the transmission requirement to 100% of FS Capacity Requirement.  Ensuring 100% deliverability is common among RA programs and appropriate as transmission is not fungible between resources except as similarly located.
• Transition to an approach that excludes PRM in setting a transmission requirement is inconsistent with the intention of a PRM.  The load value used in the Forward Showing is only a P50 load – meaning the load has a 50% chance of being higher or lower than the projected load value.  Load of closer to a P100 is included in the PRM and should not be separated from the transmission requirement.   
• The WRAP deliverability requirement is critical to ensuring transmission continues to develop as Day-ahead markets develop. Over the next few years, most of the Western entities are moving to one of two Day-Ahead LMP market offerings, neither of which contains a centralized transmission planning component. LMP markets will make transmission less economic to develop except as required by RA program requirements.  Weakening this component of the program weakens future transmission development.

In summary, APS views the subject of this proposal as one that would benefit from a more collaborative participant discussion beyond that available via the NTFP process and encourages BPA to consider other avenues for exploring changes to this component of the WRAP.