COMMENT FOR 2025 Draft PRC Workplan

Submitted April 15, 2025, 1 p.m.





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

Seattle appreciates the opportunity to comment on the Draft PRC Workplan, Task Force Schedule found in Figure 3 – Level of Effort Review Draft Task Force Schedule and understands that there needed to be a balance of staff's time between, the PA (WPP), PO (SPP), plus participant involvement in each concept's timeline. Although these were ranked using an online tool, Seattle feels like the DAM Optimization/SWEDE TX Limits, should be moved out of the 2025 schedule and replaced with number 24 Flat load and PRMs and/or number 02 Earlier FS Metrics/ Monthly volatility. Optimization in the DAM market is an indirect variable of the WRAP program where Flat Load and PRMs and Earlier FS Metrics/ Monthly PRM Volatility are directly related to how the WRAP program operates and functions and WRAP should prioritize issues that deal first with WRAP directly like the PRMs, FS metrics, and so on vs DAM optimization work as this may not pertain to all participants. Resource adequacy and reliability are two focus areas for WRAP, not DA optimization.

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

Prioritizing issues that are indirectly related to the WRAP program could impact participants binding commitments, non-participants from joining, and cause participants to flee WRAP, if WRAP places a lot of emphasis on external Day Ahead market integration/optimization, before we have the WRAP program ironed out and up and running.

03. Please supply any comments on the Executive Summary

No Comment

04. Please supply any comments on Section 1. Background

Seattle wishes the Concepts and Change Request Forms (CRFs) were shared with in person participants before the prioritization exercise began to better understand and weigh in on the grouping/narrowing down of the Concepts during the exercise. It would have been nice to hear from each participant that submitted a Concept, to better understand the participants asking and be able to ask questions of the participants.

05. Please supply any comments on Section 2. PRC Prioritization Exercise

Seattle is curious if there will be a call out to current participants to help with moving the Concepts along in a timelier manner. The draft work plan looks to go into potential binding seasons, it would be good to expedite these Concepts and proposals before any binding season happens. Would having additional participants contribute to this effort make it go faster?

06. Please supply any comments on Section 3. Detailed Level of Effort Review

Seattle would like to see the PRC and WPP prioritize the concepts that directly relate to the WRAP program first before prioritizing external market integration concepts that are not applicable to everyone in the WRAP program.

07. Please supply any comments on Section 4. Proposed Schedule and Plan of Action

No Comment

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

No Comment

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

Seattle would like to see a check box on the CRF to identify if the Concept being brought up directly relates to the WRAP program and all its participants or if it is an indirect Concept that indirectly ties the WRAP program to other potential markets or products, like CAISO EDAM or SPP Markets +. Seattle believes that this delineation will help the PRC better prioritize the Concepts, prioritizing WRAP issues first.

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

No Comment

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

No Comment

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

No Comment

General Comment

No Comment

avatar