Please supply any comments related to the proposed changes in BPM 109 - Forward Showing Transition
No response submitted.
Please supply any comments related to the proposed changes in BPM 210 - Binding and Non-Binding Participation in Operations Program
No response submitted.
Please supply any comments related to the proposed changes in the WRAP Tariff
No response submitted.
General Comment
Idaho Power strongly supports and endorses the WRAP Deficiency Charge Deferral Expedited Proposal and encourages its prompt adoption. Idaho Power views the proposed deferral mechanism as an important component of a successful transition to WRAP. During this period, providing participants with a reasonable mechanism to address qualifying deficiency charges can provide needed flexibility while participants gain experience operating under the program.
Importantly, Idaho Power believes the deferral mechanism appropriately preserves the incentive created by the deficiency charge while also preserving capital that can be deployed toward the investments necessary to address the underlying reliability need. Deferral does not eliminate the participant’s obligation or the economic consequences associated with a deficiency. Rather, it provides an opportunity for participants to direct near-term resources toward actions that can improve their future resource adequacy position, including investments in generation, transmission, demand-side resources, or other infrastructure and capabilities that support reliability.
Idaho Power believes this approach can better align the financial incentive with the behavior the WRAP is intended to encourage. Ultimately, the objective of the deficiency charge should be to incent participants to take actions that reduce future deficiencies and improve regional reliability. Where appropriate, deferral can help ensure that limited capital is available for those reliability investments rather than being immediately consumed by a charge that, by itself, may not provide a corresponding future reliability benefit.
For these reasons, Idaho Power believes the concept may continue to provide value beyond the transition period. At the same time, the design of an enduring deferral mechanism should recognize the important role deficiency charges play in maintaining strong incentives for participants to meet their WRAP obligations. As the program matures, Idaho Power would therefore support establishing additional boundaries, eligibility requirements, and appropriate safeguards around the use of deferral to ensure that it remains targeted to circumstances where it supports the desired reliability outcomes and does not dilute the underlying incentives of the program.
Idaho Power therefore fully supports adoption of the Expedited Proposal as presented and believes it represents a constructive approach that maintains accountability, preserves the appropriate economic incentive, and provides participants greater ability to invest in solutions that contribute to long-term resource adequacy and regional reliability.
Submitted Responses
2026-EP-03 (Deficiency Charge Deferral)
Please supply any comments related to the proposed changes in BPM 109 - Forward Showing Transition
Please supply any comments related to the proposed changes in BPM 210 - Binding and Non-Binding Participation in Operations Program
Please supply any comments related to the proposed changes in the WRAP Tariff
General Comment
Idaho Power strongly supports and endorses the WRAP Deficiency Charge Deferral Expedited Proposal and encourages its prompt adoption. Idaho Power views the proposed deferral mechanism as an important component of a successful transition to WRAP. During this period, providing participants with a reasonable mechanism to address qualifying deficiency charges can provide needed flexibility while participants gain experience operating under the program.
Importantly, Idaho Power believes the deferral mechanism appropriately preserves the incentive created by the deficiency charge while also preserving capital that can be deployed toward the investments necessary to address the underlying reliability need. Deferral does not eliminate the participant’s obligation or the economic consequences associated with a deficiency. Rather, it provides an opportunity for participants to direct near-term resources toward actions that can improve their future resource adequacy position, including investments in generation, transmission, demand-side resources, or other infrastructure and capabilities that support reliability.
Idaho Power believes this approach can better align the financial incentive with the behavior the WRAP is intended to encourage. Ultimately, the objective of the deficiency charge should be to incent participants to take actions that reduce future deficiencies and improve regional reliability. Where appropriate, deferral can help ensure that limited capital is available for those reliability investments rather than being immediately consumed by a charge that, by itself, may not provide a corresponding future reliability benefit.
For these reasons, Idaho Power believes the concept may continue to provide value beyond the transition period. At the same time, the design of an enduring deferral mechanism should recognize the important role deficiency charges play in maintaining strong incentives for participants to meet their WRAP obligations. As the program matures, Idaho Power would therefore support establishing additional boundaries, eligibility requirements, and appropriate safeguards around the use of deferral to ensure that it remains targeted to circumstances where it supports the desired reliability outcomes and does not dilute the underlying incentives of the program.
Idaho Power therefore fully supports adoption of the Expedited Proposal as presented and believes it represents a constructive approach that maintains accountability, preserves the appropriate economic incentive, and provides participants greater ability to invest in solutions that contribute to long-term resource adequacy and regional reliability.