01. Please supply any comments on the draft Task Force Schedule found in Figure 3

PGE supports all proposed changes and appreciates the opportunity to provide comments. While all proposed changes are important and PGE expects that they will enhance the program's design, PGE considers Concept 02 to be crucial to be implemented as soon as possible and proposes moving it up to the 2025 work plan. Additionally, PGE finds Concept 12 very important and believes it should be completed well before the first WRAP binding season to ensure the contribution of existing VERs is accurately reflected. Therefore, PGE would propose that Concept 12 is also moved up to 2025. To accommodate for these changes, PGE suggests switching Concepts 05 and 03 to the 2026 workplan. PGE also expresses its concerns regarding the impacts that emerging day-ahead markets, such as EDAM, scheduled to go live in 2026, will have on WRAP. Addressing these impacts in an accelerated manner is essential, as there may be inconsistencies between the setup of these markets and the design of WRAP that need to be resolved before the WRAP first binding season.

02. Please supply any comments on Concepts that could impact a commitment to go Binding or remaining in the WRAP

Consolidated Concept 02 (Earlier FS Metrics / Monthly Volatility): The draft PRC Workplan proposes a timeline for completing this concept by June 2026. This timeline addresses the issue after October 2025, the deadline for changing the first binding season, and does not provide sufficient assurance that the PRMs applied to Winter and Summer shoulder months (i.e., June, September, November, March) will be reasonable when the program becomes binding. Runaway PRMs of up to nearly 30% during WRAP shoulder months and the PRM volatility between Advance Assessments pose significant risks to PGE's ability to plan adequately and meet WRAP capacity requirements during those months. The monthly PRM volatility can also lead to financial exposure from either a WRAP deficiency charges, or term capacity contracts needed to cover oversized peak load forecasts during WRAP seasons shoulder months that we would not expect in operations. The PRM uncertainty is an important factor in PGE’s decision to maintain the first binding season as Winter 2027-2028. To resolve this issue, along with the consolidated Concept 15 – Planned Outage Clarification, the program could consider reducing the number of days or entirely removing the shoulder months (i.e., June and September, and November and March, respectively) from the Summer and Winter WRAP seasons. Consolidated Concept 12 (ELCC by Vintage, Indicative QCC for LTS): PGE strongly supports the proposed changes in this concept, emphasizing their critical importance for implementation before the first binding season. Similar to Concept 02, the draft PRC workplan aims to complete this change by June 2026. However, this timeline does not align with the decision to maintain the first binding season due in October 2025. PGE advocates for the design change to ensure that the capacity contribution of existing variable energy resources (VERs) remains unaffected by the penetration of other VERs. Instead, only the capacity contribution of new VERs should be impacted. The current WRAP design can lead to QCC variations for existing resources, potentially reducing participants' resource supply QCCs even if their portfolios remain unchanged. Consolidated Concept 01 (DAM Consolidation/SWEDE TX Limits): WRAP design needs to align with day-ahead market (DAM) requirements. Therefore, any DAM-related enhancements should be prioritized, and WRAP design should remain flexible to accommodate potential changes as day-ahead markets come online as early as 2026. Unresolved design inconsistencies between WRAP and day-ahead markets before the first binding season could impact PGE’s decision to participate. Consolidated Concept 15 (Planned Outage Clarification): Utilities typically schedule planned outages during months with lower expected loads, including WRAP shoulder months such as June, September, November, and March. The combination of these planned outages and the extremely high PRMs calculated for these months often results in a deficit position in the WRAP Forward Showing, leading to potential significant deficiency charges. PGE emphasizes the importance of resolving and implementing this proposed change well in advance of the first binding season FS submittal.

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

No response submitted.

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

PGE is proposing that Concepts 02 and 12 be moved up to the 2025 workplan. To accommodate for these changes, PGE suggests switching Concepts 05 and 03 to the 2026 workplan.

08. Please supply any comments on Section 6. Next Steps

No response submitted.

09. Please supply any comments on Appendix A - Change Request Form Compilation

No response submitted.

10. Please supply any comments on Appendix B - PRC Minutes Dec. 18th, 2024

No response submitted.

11. Please supply any comments on Appendix C - PRC Minutes Jan. 23rd, 2025

No response submitted.

12. Please supply any comments on Appendix D - PRC Minutes Feb. 19th, 2025

No response submitted.

General Comment