01. Please supply any comments on the draft Task Force Schedule found in Figure 3

The Draft Task Force Schedule identified in figure 3 was created by the PRC as a prioritization of concepts submitted through Change Request Forms in December 2024. Bonneville appreciates the Western Power Pool’s leadership in this process and has participated in and continues to support WRAP in general and this PRC prioritization process specifically. Bonneville also recognizes that the industry is in a period of significant change with the ongoing development of Day Ahead Markets (DAM). Both priorities and concepts addressed by WRAP will at times need to be adjusted accordingly. Bonneville proposes the program should work toward providing as much certainty as possible by October of this year on how the program will interact with organized markets and operate in binding seasons. Bonneville encourages the PRC to be flexible enough to adjust the annual plan as issues become priorities or new issues overtake those that have been identified and prioritized in the plan. Since this workplan was approved, the timeline associated with certain EDAM participants has become clear for a start in 2026. In addition, Bonneville’s scoping of future market implementation with the very real possibility that portions of our generation and load will be in different markets has revealed it is imperative to make sure WRAP integrates well with DAMs (regardless of which market a WRAP participant plans to join). WRAP must provide clarity of how its participants meet program compliance requirements (holdback and energy deployments) when load and generation are in different markets. This will require adjustments to the WRAP program. Bonneville believes the PRC work plan identifies many of the known issues and appropriately prioritizes them. We want to highlight the importance of Concept 01 that directly takes on some of the organized market issues and encourage the PRC to expand this concept’s scope, so as to address several other DAM/WRAP interface concerns beyond WRAP holdbacks and SWEDE transmission limits. Bonneville also wants to call attention to Concept 02, which deals with FS metrics (PRM) and the extreme volatility this is causing from month to month in the program. We recognize that both are prioritized below Concept 05 that deals with Load Growth Factors. As issues have evolved in Bonneville’s scoping of DAM implementation since the January PRC approval of this plan, we see these both as having greater effects on participants continuing to be able to participate in the program. While Concept 05 is highly important, we view it as something that must be updated but may be a lower priority when considering the decision points that are coming for participants in October 2025 and January 2026. Bonneville asks that Concept 01 be expanded, Concept 02 be moved up to July of 2025 and Concept 05 be delayed into 2026.

02. Please supply any comments on Concepts that could impact a commitment to go Binding or remaining in the WRAP

October is a key decision point for current participants as it is the deadline to notify the program if a participant intends to exit before the program becomes binding. Many issues remain to be resolved in the WRAP design which is illustrated by the number of Concepts submitted in December. For very practical reasons, many Concepts were not prioritized for the 2025 workplan, including how a participant operates in the Operations program when it has load in both regions of the program. Bonneville believes participants need clarity on how WRAP will work with DAMs to provide the Resource Adequacy services that the program was designed to provide. The design was based on a bi-lateral construct and must be adjusted to work with organized markets that will dispatch resources to meet all load. In addition, participants also need a clear understanding of what the Operations program looks like when a participant has loads and generation in both regions. This needs to be addressed by October for example by clarifying dual region operations, or by revising the program so that all entities operate in a single region. The October deadline (for the 2-year exit provision) will be the point participants are evaluating financial risks for Winter 2027/2028. It is important that WRAP has addressed or mapped a path forward on the key issues at that decision point to give participants confidence that those future risks can be mitigated, while also recognizing much more can be addressed and resolved in the two-year period before the first binding season starts.

03. Please supply any comments on the Executive Summary

Bonneville would like to see a statement included in the executive summary reflecting the need for the Workplan to remain flexible in addressing rapidly evolving issues.

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

Section 4 addresses concepts that have been prioritized and states that the PRC as a whole has the responsibility for a concept after it is part of the workplan. Section 4 also states that the PRC will move on to other items if time allows. Bonneville supports an addition to this section to identify that the PRC has the flexibility to shift priorities, workplan purpose, or schedule if the PRC were presented with a concept that was considered urgent. Such flexibility could be enacted as an immediate request to BOD for a change. We do recognize that the Governance process has other paths for changes to be made, however we want to recognize this PRC process as being the most complete and collaborative process. The program is strengthened by significant issues being addressed by the broadest coalition of WRAP members possible.

08. Please supply any comments on Section 6. Next Steps

No response submitted.

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

No response submitted.

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

No response submitted.

11. Please supply any comments on Appendix C - PRC Minutes Jan. 23rd, 2025

No response submitted.

12. Please supply any comments on Appendix D - PRC Minutes Feb. 19th, 2025

No response submitted.

General Comment

Bonneville thanks the WPP, the PRC, and WRAP members for all the hard work that has gone into developing the CRF workplan structure. 

Bonneville remains very committed to WRAP’s mission and success. To support the program’s success, we propose the above adjustments to the current workplan structure to allow for resolution of these and other issues. Working to maximize clarity on the program’s future operations will allow members to be confident in a decision to continue past October in this extremely important program.