2024-CRF-01 Day Ahead Market Optimization / SWEDE Limits (Long)

As a sponsor of this change request, APS is automatically assumed to be a member of this task force. APS does wish to participate as a member of this task force. Specifically, Tyler Moore will be our representative on this task force. He was actively engaged in the working group during the tariff and protocol development of EDAM, Markets+ and WRAP. Further, he is currently the chairman of the Markets+ Resource Adequacy Task force. His deep understanding of the construct of both Day-Ahead markets and the WRAP will be an asset for this working group.

2024-CRF-02 Earlier FS Metrics / Monthly Volatility (Long)

APS would like to participate as a member of this task force. APS has participated in all non-binding forward showings since joining the WRAP program in 2022. Based on this experience, APS shares some of the same concerns brought forth by NVE regarding the timing of the availability of Forward Showing metrics and the challenges with taking meaningful action in the resource procurement space to fill any potential shortcomings to the Forward Showing. APS has extensive knowledge and experience in the resource planning space that would benefit this task force. APS would specifically assign Brandon Holmes to this task force. Brandon works very closely with our Resource Planning team as well as the Operations team who submits the forward showing and can pull in different subject matter experts from those groups to support the task force as needed.

2024-CRF-03 Demand Response QCC (Medium)

As a sponsor of this change request, APS is automatically assumed to be a member of this task force. APS does wish to participate as a member of this task force. APS has extensive experience with demand response program. Nameplate capacity of current DR programs is 200MW+, with the expectation of the nameplate capacity from those programs more than doubling over the next 10 years. We will identify a specific individual for participation in this task force at a future date.

2024-CRF-05 Load Growth Factor (Long)

As a sponsor of this change request, APS is automatically assumed to be a member of this task force. APS does wish to participate as a member of this task force. APS’ service territory has experienced significant load growth recently, which is expected to continue into the future. We intend to make subject matter experts available to the task force as requested. A specific individual from our organization will be identified at a later date for direct participation in this task force.

2024-CRF-08 CAISO Firm Transmission (Short)

As a co-sponsor of this change request, APS is automatically assumed to be a member of this task force. APS has confidence that the task force can work through this without representation from APS, so we are opting out of direct membership in this task force. One point of scoping clarification that we wanted to flag is that this task force should be looking at both the CAISO Wheel Through rules (included in the description of the change request) and the CAISO Non-RA high priority exports. The latter was included as part of 2024-CRF-007 that APS originally submitted but then closed and signed onto 2024-CRF-008 to help facilitate consolidation ahead of the PRC prioritization exercise in January.

2024-CRF-10 Capability Testing Off-Season (Short)

APS would like to participate as a member of this task force. APS has participated in all non-binding forward showings since joining the WRAP program in 2022 while completing many capability tests on our resources which will allow for APS to participate with meaningful perspectives in this task force. A specific individual from our organization will be identified at a later date for direct participation in this task force.

2024-CRF-12 ELCC by Vintage / Indicative QCC for Long-Term Storage (Long)

As a sponsor of this change request, APS is automatically assumed to be a member of this task force. APS does wish to participate as a member of this task force. We intend to make subject matter experts available to the task force as requested. A specific individual from our organization will be identified at a later date for direct participation in this task force.

2024-CRF-14 Joint Owner Flexibility (Short)

No response submitted.

2024-CRF-15 Planned Outage Clarification (Short)

APS would like to participate as a member of this task force. APS has participated in all non-binding forward showings since joining the WRAP program in 2022 and has previously provided detailed design considerations around planned outage incorporation into WRAP which will allow APS to provide additional meaningful perspectives in this task force. A specific individual from our organization will be identified at a later date for direct participation in this task force.

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