01. Please supply any comments on the draft Task Force Schedule found in Figure 5 (Schedule III)
NorthWestern appreciates the PRC’s, WPP’s, and RAPC’s thoughtful prioritization of the 2025 CRFs in the PRC’s 2026 DRAFT Workplan. In regard to NorthWestern and Renewable Northwest’s joint 2025-CRF-9/10, NorthWestern requests that the PRC clarify the “Workgroup (White paper)” stream, occurring in August/September 2026, to specifically indicate the following:
“2025-CRF-9/10 concept sponsors and any additional interested parties, known as the Regional Transmission Workgroup, will meet as necessary during the months of August and September 2026, along with assigned WPP and SPP personnel, to draft preliminary indicative policy regarding the treatment of new regional transmission in the program. Additionally, the Workgroup will work with SPP and WPP staff to define and plan modeling work, possibly within the 2026 Advanced Assessment LOLE modeling (for the S28 & W28-29 seasons), to quantify the potential of:
1) NPC Project Diversity Transfers & FS PRM Decremental Effect
2) NPC Project as a Qualifying Resource with defined Qualifying Capacity Contribution (QCC) values”
These two additional NPC Project scenarios would be in addition to the study work outlined in the S28 & W28-29 Study Scope Document. The Summer 2028 LOLE Studies should be completed by 10/31/26 and the Winter 28-29 LOLE Studies should be completed by 3/31/27. NorthWestern requests that SPP provide the Regional Transmission Workgroup with the NPC Project S28 and W28-29 scenario LOLE modeling results as soon as the results become available. The modeling results would be valuable to the Regional Transmission Workgroup in assessing the potential value that regional transmission projects could provide to WRAP participants.
The Regional Transmission Workgroup and any additional interested parties would convene in April 2027 to form the Regional Transmission Task Force. This Regional Transmission Task Force would discuss the results of SPP’s NPC Project LOLE modeling and further develop the 2025-CRF-9/10 concepts into a formal Proposal during the period April 2027 through October 2027.
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
NorthWestern would like to thank the PRC for formally prioritizing NorthWestern and Renewable Northwest’s joint 2025-CRF-9/10 as the second highest 2025 Change Request Form ranking during the PRC’s 1/28/26 meeting. The high prioritization of 2025-CRF-9/10 reflects the PRC’s recognition of the very high value proposition that regional transmission projects could provide to the WRAP.
06. Please supply any comments on Section 3. Detailed Level of Effort Review
No response submitted.
07. Please supply any comments on Section 4. Proposed Schedule and Plan of Action
No response submitted.
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