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

Grid United appreciates the extensive work reflected in the Draft 2026 Workplan and commends the PRC for maintaining flexibility ahead of the first binding season. We recognize that interregional transmission concepts, including 2025 CRF 09/10 REGIONAL TX (FOR CAPACITY), were initially ranked as the second highest priority during the PRC prioritization exercise on January 28, 2026. We further acknowledge that, through subsequent discussions, these concepts were deprioritized relative to efforts viewed as having more “immediately deliverable outcomes” prior to the first binding Forward Showing. While Grid United understands and respects the need to focus on near term binding readiness, we believe that the interregional transmission workstream is uniquely positioned to advance efficiently and with relatively modest incremental burden on WPP and SPP staff. Grid United has existing technical expertise, prior stakeholder engagement, and licensed modeling capabilities using SERVM, the same production cost and reliability modeling platform currently relied upon by SPP and WRAP. Leveraging this foundation, Grid United believes that meaningful progress on this concept can be achieved through a short or medium level of effort rather than a Long six month Task Force cycle. With respect to the August–September workgroup contemplated for development of a white paper related to 2025 CRF 09/10, Grid United respectfully seeks clarity regarding the intended outcome of this process. Grid United stands ready to contribute staff time and analytical resources to support a structured, transparent, and technically grounded effort that results in a clearly articulated preliminary policy proposal supported by modeling results. In our view, a focused two month white paper effort has the potential to substantially narrow outstanding policy questions and reduce the scope of subsequent Task Force work. Accordingly, Grid United encourages the PRC to view the white paper process as an opportunity to materially reduce the remaining time required to complete this workstream. Successful completion should enable the PRC to reconsider the current “Long” time score assigned to 2025 CRF 09/10 and potentially advance the full Task Force effort on an accelerated schedule more commensurate with its original prioritization and broad stakeholder interest. Prioritizing this effort would provide needed policy clarity for interregional transmission investments such as North Plains Connector that have the potential to deliver material capacity value to the WRAP, thereby reducing uncertainty and encouraging development of additional projects that benefit WRAP participants. This workstream should be treated as a priority given the magnitude of potential savings for participants and their ratepayers. Preliminary Grid United analysis indicates that the North Plains Connector alone could yield on the order of 1,500 MW (1,500,000 kW) of capacity value to the WRAP, equivalent to approximately $138 million per year when applying the 2022 WRAP CONE of $91.81 per kW‑year. These estimates are conservative, as they rely on an outdated CONE value and do not capture the growing diversity of the eastern and western grids.

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

No response submitted.

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

Grid United seeks clarification regarding the apparent inconsistency in the timing of the 2025‑CRF‑09/10 Regional Transmission for Capacity Task Force as depicted across figures in the Draft Workplan. Specifically, Figure 3 appears to indicate a January 2027 start, while Figure 5 suggests an April 2027 initiation. More broadly, Grid United appreciates the PRC’s recognition of staff and stakeholder bandwidth constraints as reflected in the level of effort review. At the same time, we believe the long-time score currently assigned to 2025‑CRF‑09/10 overstates the incremental effort required to advance this concept, particularly given the availability of participant‑led analytical support. Grid United is prepared to coordinate closely with WPP and SPP staff and WRAP stakeholders to execute a transparent study process that accelerates progress while maintaining technical rigor and stakeholder confidence. In our view, a participant‑supported modeling effort that aligns with existing SERVM methodologies can significantly reduce staff burden and shorten development timelines, allowing this important concept to advance without detracting from higher‑priority binding season preparations.

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

Grid United appreciates and strongly supports the PRC’s stated commitment to flexibility in the Draft 2026 Workplan, including its recognition that while Concept Prioritization should remain the foundation of the Workplan, the PRC should retain discretion to respond to special circumstances such as shifts in priorities, staffing availability, or workstream readiness. We are encouraged by this approach and view it as particularly relevant to 2025‑CRF‑09/10 because it was initially voted as the second top priority for 2026. Should the proposed white paper and associated analytical work result in a clear, well‑supported preliminary policy proposal with broad stakeholder alignment, Grid United respectfully requests that the PRC consider using this built‑in flexibility to reassess the timing and priority of this effort. Doing so would be consistent with the Workplan’s stated intent and would allow the PRC to advance a mature, high‑value policy outcome without disrupting near‑term binding‑season readiness.

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

Grid United respectfully submits the following comments on the Draft PRC 2026 Workplan. We appreciate the significant effort undertaken by the PRC, WPP staff, and RAPC to align the Workplan with participant needs as the WRAP prepares for its first binding Forward Showing deadline of March 31, 2027, for Winter 2027–2028. The Draft Workplan reflects a thoughtful balancing of ambition, staff bandwidth, and participant readiness during a critical program transition.