01. Please provide any comments on the proposal to adjust the timing of the FSPRM calculation (LOLE Study).

No response submitted.

02. Please provide any comments on modifying the duration of the Winter Binding Season.

No response submitted.

03. Please provide any comment on the proposed updates to the methodology of the LOLE Study.

No response submitted.

04. Please provide any comment on the Implementation Plan and Feasibility section of the proposal including Risks, Schedule, and Impacts.

No response submitted.

05. Please provide any comments on the redlines to WRAP Tariff.

No response submitted.

06. Please provide any comments on the redlines to BPM 101 – Advance Assessment.

No response submitted.

07. Please provide any comments on the redlines to BPM 102 – Forward Showing Reliability Metrics.

No response submitted.

08. Please provide any comments on the redlines to BPM 103 – Participant Forward Showing Capacity Requirements.

No response submitted.

09. Please provide any comments on the redlines to BPM 104 – Capacity Critical Hours.

No response submitted.

10. Please provide any comments on the redlines to BPM 105 – Qualifying Resources.

No response submitted.

11. Please provide any comments on the redlines to BPM 108 – Forward Showing Submittal Process.

No response submitted.

12. Please provide any comments on the redlines to BPM 109 – Forward Showing Transition Period.

No response submitted.

13. Please provide any comments on the redlines to BPM 401 – New Participant Onboarding.

No response submitted.

General Comment

Idaho Power would like to thank the PRM Task Force for the extensive work, collaboration, and analysis that went into developing this proposal. Idaho Power understands that this proposal is the result of months of thoughtful discussion, modeling effort, and coordination among participants, WPP and SPP. We also acknowledge the complexity involved in reevaluating the process for setting PRMs. With varying load shapes, resource portfolios, and levels of exposure to PRM volatility amongst participants, there is no single “one‑size‑fits‑all” solution. This proposal’s effort to reconcile these differences into a unified, program‑wide approach is commendable. Idaho Power is supportive of the majority of the concepts put forward by the Task Force, and offers suggestions on a few areas of remaining concern, including the five- and ten-year FSPRMs.

Idaho Power is supportive of the majority of the concepts presented in this proposal including:

• Adjusting the timing of the LOLE studies to allow earlier disclosure of binding FSPRMs;
• Modifying the duration of the binding Winter Season;
• Changes to the LOLE study, including the shifting of LOLE risk to Non-Peak Months, limiting historical weather data to 40 years, and aligning the LOLE study treatment of contingency reserves with RSG requirements; and
• Implementing a Seasonal Peak Load approach to the Summer Season for the months of July and August

Idaho Power is in favor of setting binding FSPRMs earlier than the current process allows for, which sets binding FSPRMs 9 months ahead of the FS deadline. The company believes earlier setting of the binding FSPRMS will benefit long-term viability of the program. Specifically, by setting the binding FSPRMs earlier, participants will have improved visibility into future obligations and more time to secure needed resources and mitigate compliance risk. 

The company is also encouraged by the PRM Task Force’s proposal to adjust LOLE risk allocated across the months of the season, while maintaining the 1‑in‑10 reliability standard over the entire season. Idaho Power believes this change will more accurately align capacity requirements with loss of load risk, i.e., capacity requirements will be lower in Non-Peak Months when loss of load is less likely to occur.

While Idaho Power is largely supportive of the proposal as written, it offers the following suggestions to the PRM Task Force for consideration. 

Idaho Power recognizes there is a tradeoff in setting the binding FSPRMs 5 years ahead of the FS deadline, which is less accuracy in load and resource assumptions used to set the binding FSPRMs and potentially increased FSPRM volatility. Specifically, lower accuracy in load and resource assumptions looking ahead five-plus years could lead to relatively higher FSPRMs, compared to the PRMs that might result from using closer-in-time, more accurate load and resource information. As mentioned above, Idaho Power recognizes the benefits of locking in the FSPRMs further in advance, and is supportive of the concept, but is concerned that the uncertainty that may still exist in loads and resources five-plus years into the future could lead to FSPRMs that are unrealistic.

There may be a few alternative ways to mitigate this issue. One potential option could be to allow greater time between participants receiving the draft FSPRM results and the deadline for study completion to allow a more rigorous process of reviewing input data and the draft FSPRM results, as well as allowing time to conduct any updated modeling. 

Another option could be for the FSPRM modeling to consider a range of scenarios: high and low load; and the associated resources with each; with the ultimate PRMs being within those bookend cases; or for the FSPRMs to be set at a point that is less than five years in advance (i.e., potentially three years could be an option). 

Another option could be to allow for additional review or participant comment after the final FSPRMs are determined but before they go to the WPP Board for approval. The Board should have the flexibility to consider the FSPRMs and approve them, not approve them, or defer approval until after additional modeling is completed, even if the ultimate binding PRM is set at a point that is less than 5 years advance. Idaho Power is not suggesting any form of restudy after the binding FSPRMs have been set. 

Idaho Power welcomes the Task Force’s thoughts and creativity on this issue and the options to address it, and how the binding FSPRMs with further advance notice might be implemented in terms of setting values that are realistic and reasonable.

The company also questions whether the 10-year advisory FSPRMs are necessary. Given the evolving energy landscape, participants’ load and resource assumptions used to determine the 10-year advisory FSPRMs will likely be stale and inaccurate, and therefore the results invalid. Additionally, relieving the Program Operator of conducting a 10-year advisory study may create additional bandwidth to conduct a more comprehensive review of draft 5-year FSPRM results, and any updated modeling needed, as mentioned above. 

Finally, Idaho Power understands the PRM Task Force’s need to limit scope and avoid scope creep, whereby it proposed to defer changes to P50 Peak Load Forecast methodology and QCC/ELCC design to future task forces. However, the company would like to reiterate the importance of establishing the PRM Task Force proposed changes as guardrails to the upcoming Load Forecasting and QCC/ELCC Task Forces so that those efforts do not inadvertently undermine gains achieved in this task force or overlook interactions of these components and the implications. 

Overall, this proposal represents a thoughtful evolution of WRAP’s PRM framework. It takes meaningful steps toward improving predictability, reducing volatility, and better aligning monthly and seasonal requirements with actual reliability risk. Again, Idaho Power appreciates the balanced approach taken to address diverse participant needs.

Thank you for the opportunity to review and comment on this proposal.