Please supply any comments related to the proposed changes in BPM 101 - Advance Assessment
No response submitted.
Please supply any comments related to the proposed changes in BPM 108 - FS Submittal Process
No response submitted.
Please supply any comments related to the proposed changes in the WRAP Tariff
No response submitted.
General Comment
Black Hills Colorado Electric appreciates the opportunity to comment on EP-06. BHCE supports the proposed revisions related to the Rockies Subregion Forward Showing deadline and associated timeline adjustments.
As WPP notes in the proposal, the creation of the Rockies Subregion presented a unique timing challenge because there were no Rockies participants at the time the standard WRAP deadlines occurred and therefore no established FSPRMs for the subregion. Since then, significant progress has been made to support implementation of the Rockies Subregion. In particular, stakeholders have worked collaboratively to develop solutions that recognize the unique circumstances associated with bringing a new subregion into WRAP.
BHCE appreciates the flexibility shown by WPP staff and WRAP stakeholders throughout this process. The willingness to work through stakeholder concerns and develop practical transition solutions has helped create a workable path forward for potential Rockies participants.
While BHCE previously raised concerns regarding the waiver request filed earlier this year, the stakeholder process has since produced a more complete solution that includes both revised timelines and transition provisions for Rockies participants. We believe the proposal provides a reasonable path forward and supports participation in the Winter 2027-2028 WRAP Binding Season for the subregion.
BHCE also supports the proposed timeline modifications, which maintain a seven-month period between FSPRM approval and the Forward Showing deadline while preserving the existing 60-day cure period for participants. These adjustments appropriately balance the need to onboard the Rockies Subregion with the broader WRAP implementation schedule.
As BHCE continues evaluating its resource adequacy requirements and market participation options, the metrics, information, timelines, and transition framework reflected in this proposal will be helpful in informing those evaluations.
For these reasons, BHCE supports EP-06 and appreciates the efforts of WPP staff and stakeholders to develop a practical and collaborative solution for the Rockies Subregion.
Submitted Responses
2026-EP-06 (Rockies FS Deadline)
Please supply any comments related to the proposed changes in BPM 101 - Advance Assessment
Please supply any comments related to the proposed changes in BPM 108 - FS Submittal Process
Please supply any comments related to the proposed changes in the WRAP Tariff
General Comment
Black Hills Colorado Electric appreciates the opportunity to comment on EP-06. BHCE supports the proposed revisions related to the Rockies Subregion Forward Showing deadline and associated timeline adjustments.
As WPP notes in the proposal, the creation of the Rockies Subregion presented a unique timing challenge because there were no Rockies participants at the time the standard WRAP deadlines occurred and therefore no established FSPRMs for the subregion. Since then, significant progress has been made to support implementation of the Rockies Subregion. In particular, stakeholders have worked collaboratively to develop solutions that recognize the unique circumstances associated with bringing a new subregion into WRAP.
BHCE appreciates the flexibility shown by WPP staff and WRAP stakeholders throughout this process. The willingness to work through stakeholder concerns and develop practical transition solutions has helped create a workable path forward for potential Rockies participants.
While BHCE previously raised concerns regarding the waiver request filed earlier this year, the stakeholder process has since produced a more complete solution that includes both revised timelines and transition provisions for Rockies participants. We believe the proposal provides a reasonable path forward and supports participation in the Winter 2027-2028 WRAP Binding Season for the subregion.
BHCE also supports the proposed timeline modifications, which maintain a seven-month period between FSPRM approval and the Forward Showing deadline while preserving the existing 60-day cure period for participants. These adjustments appropriately balance the need to onboard the Rockies Subregion with the broader WRAP implementation schedule.
As BHCE continues evaluating its resource adequacy requirements and market participation options, the metrics, information, timelines, and transition framework reflected in this proposal will be helpful in informing those evaluations.
For these reasons, BHCE supports EP-06 and appreciates the efforts of WPP staff and stakeholders to develop a practical and collaborative solution for the Rockies Subregion.
Respectfully,
Kerri Schlachter
Black Hills Energy