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

Seattle supports improving planning certainty through earlier visibility into Forward Showing Planning Reserve Margin (FSPRM) values. However, advancing FSPRM approval five years ahead of the binding season does not solve Seattle’s primary concern with the proposal, which is the continued misalignment between modeled monthly PRMs and observed reliability risk, particularly in June. Establishing metrics further in advance increases the importance of ensuring that monthly PRM outcomes are proportionate to actual system risk. If Monthly values remain overstated in shoulder months, advancing the timeline may lock in requirements that are not reflective of real-world reliability needs and may be difficult for participants to adjust to once set. Seattle recommends that improvements to timing be paired with additional refinement of the LOLE methodology so that earlier metrices reflect a more accurate distribution of risk across months. Without such refinement, earlier FSPRMs may provide planning certainty but still embed structural issues in monthly PRM outcomes.

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

Seattle supports efforts to align binding season definitions with periods of highest reliability risk. Adjusting the Winter Binding Season to better match modeled loss of load risk is a reasonable step and appears analytically supported. However, Seattle notes that while winter season boundaries are being refined to better reflect risk, similar attention is needed for the summer shoulder period. In particular, June continues to reflect a high PRM despite being characterized as a non-peak month. From Seattle’s perspectives this suggests that the methodology adjustments have not fully resolved the misalignment between modeled risk and monthly capacity requirements. Seattle supports refining season definitions but emphasizes that addressing shoulder month PRMs especially June is equally important to ensuring that monthly obligations reflect actual reliability risk across the year.

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

Seattle appreciates the Task Force’s work to address monthly PRM volatility and better distribute LOLE risk across the months. The objective of improving stability and predictability in monthly requirements is important as WRAP transitions into a binding program. However, Seattle does not support the current treatment of June under the proposal. While June is identified as a non-peak month, it continues to carry a comparatively high PRM that does not appear proportionate to observed system risk or regional operating conditions. From Seattle’s perspective, this indicates that the proposed redistribution of LOLE risk has not sufficiently corrected shoulder month outcomes. Maintaining a high PRM in June creates planning and procurement challenges for participants and risks shifting capacity obligations into periods where reliability risk is comparatively lower. This outcome undermines the proposal’s stated objective of aligning monthly requirements with modeled risk and reducing volatility. Seattle recommends that the Task Force: • Re-examine the minimum LOLE risk allocation assigned to June • Provide additional transparency into how risk is being distributed across peak and non-peak months • Conduct sensitivity analysis on June PRM outcomes using alternate risk allocation approaches. • Consider whether June should carry a lower minimum threshold consistent with classification as a non-peak month. Seattle supports efforts to improve stability but believes the methodology requires further refinement to ensure June requirements are proportionate to actual system reliability risk.

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

Seattle appreciates the phased implementation plan and the effort to transition thoughtfully to the proposed methodology. The staged rollout provides participants with time to adjust planning processes and understand the new framework. However, Seattle notes that implementing earlier FSPRM metrics and revised methodology without addressing the continued elevation of June PRMs may embed the very volatility and misalignment the proposal seeks to correct. If June continues to reflect a high PRM, advancing the timeline and locking in metrics further in advance could increase planning risk for participants. Seattle recommends that the Task Force consider additional review of shoulder month outcomes particularly June, before full implementation of the revised methodology. Ensuring that monthly PRM’s are proportionate to risk will improve the effectiveness of the implementation plan and increase participant confidence in the resulting metrics.

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

Seattle appreciates the significant effort of the PRM Task Force to improve planning certainty and reduce month-to-month volatility in WRAP capacity requirements. These are important objectives as the program transitions toward a binding framework, and Seattle supports continued work to improve transparency, predictability, and proportionality in the PRM methodology.

However, Seattle cannot support the proposal as currently drafted due to the continued treatment of June within the LOLE methodology and resulting monthly PRM outcomes. While June is identified as a non-peak month, the proposal continues to produce a comparatively high PRM that does not align with observed system risk, hydro conditions, or regional load patterns for that period. From Seattle’s perspective, this indicates that the proposal has not sufficiently resolved the core issues of shoulder month PRM misalignment.

Under current and proposed outcomes, June PRM requirements have potential to push participant capacity obligations hundreds of megawatts above historical June peak levels. This creates a material disconnect between modeled requirements and actual system conditions and introduces procurement and operations challenges that are not commensurate with reliability risk. Maintaining a high PRM in June places a disproportionate obligation on participants and shifts capacity requirements into a month where regional reliability risk is comparatively lower. This outcome runs counter to the stated objectives of improving stability and aligning monthly requirements with actual risk.

Seattle previously submitted a WRAP Change Request proposing a targeted shoulder-month PRM exception mechanism. As written, that proposal contemplated a limited exception when a monthly PRM would require capacity levels that materially exceed the participants historical peak for that month. In some cases, by several hundred megawatts, and where such an outcome is not supported by underlying reliability conditions. That concept remains directly relevant to the concerns raised here and may provide a practical off-ramp if monthly modeling outcomes continue to produce disproportionate requirements in June or other non-peak months.

Seattle supports the broader goals of improving timing and reducing volatility but believes the proposal requires further refinement before adoption. Specifically, Seattle recommends that the Task Force reconsider the treatment of June within the LOLE risk allocation framework and ensure that June PRM levels are proportionate to actual reliability risk.

Absent further adjustment resulting in a lower June PRM, or the inclusion of a clear and workable shoulder-month exception framework, Seattle cannot support the proposal in its current form. Addressing this issue is necessary to ensure the methodology produces monthly requirements that are aligned with reliability risk, operationally reasonable, and workable for participants across both regions.