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

Idaho Power appreciates BPA's work in describing the issue presented in this NTFP, as well as, providing redlines to the applicable BPMs and tariff. The proposal elicited the following questions for Idaho Power.   

Why propose to remove the PRM from the Forward Showing transmission requirement calculation rather than simply lowering the overall transmission requirement percentage from 75% to a lower value? Wouldn't adjusting the percentage provide a more flexible approach while still maintaining a direct link between transmission and the total capacity requirement? Additionally, has any analysis been done to review the impact to reliability, resource adequacy, and the Western Resource Adequacy Program’s goals if the transmission requirement is reduced? 

Thank you for the opportunity to provide comments.