01. Please supply any comments on the draft Task Force Schedule found in Figure 5 (Schedule III)
Renewable Northwest (“RNW”) appreciates the opportunity to comment on the Draft Workplan, specifically regarding the approach of the draft Task Force Schedule toward the combined RNW-Interwest Energy Alliance-GridLab-Northwestern Energy (“NWE”) 2025-CRF-9/10 addressing interregional transmission.
RNW was pleased that 2025-CRF-9/10 received the second-highest prioritization at the January 28, 2026 Program Review Committee (“PRC”) meeting. This prioritization appears to reflect a broad, cross-sector consensus that relieving transmission constraints and improving interregional connectivity will support regional adequacy and offer solutions to problems facing the western electricity grid.
The draft Task Force Schedule attempts to balance that high priority with the need to address certain program changes for WRAP participants before the March 31, 2027 Forward Showing (“FS”) Deadline. Accordingly, rather than standing up a full interregional transmission Task Force in 2026, the Task Force Schedule contemplates developing a white paper on the topic in Q3 2026 then convening a Task Force in Q2 2027.
Regarding the white paper, RNW supports the comments of NWE. Specifically, RNW requests that the process of developing the white paper be open and, at a minimum, include representatives from the concept sponsors. RNW also requests that white paper development include modeling to assess both PRM and QCC methods for crediting the value of transmission for resource adequacy. RNW understands that Grid United, the developer of the interregional North Plains Connector transmission line, has offered the use of its in-house ELCC software, SERVM, to support this modeling effort. RNW encourages WPP to work with Grid United on appropriate modeling to support eventual program changes.
Regarding the Task Force, RNW requests that the final Workplan explicitly reflect the flexibility to accelerate the start date ahead of April 2027 if possible. RNW appreciates that the April 2027 date immediately follows the March 31, 2027 FS Deadline that is driving the accelerated time frame for some other Task Forces, and that the approach currently reflected in the draft Workplan allows Task Forces with time-sensitive work before the FS Deadline to go first in time while still making progress on interregional transmission. Including language acknowledging the possible acceleration of the interregional transmission Task Force would similarly reflect the high prioritization of this Task Force’s work. Accelerating the Task Force may also be appropriate if the contemplated white paper offers a clear path forward on interregional transmission.
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
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
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
RNW appreciates that WRAP’s governance process channels the change process through the PRC, the body reflecting broad, sector-based representation. In approving the WRAP Tariff, FERC specifically found that the “governance structure” – including the PRC, which comprises representatives of interested sectors as well as participants – “strikes a reasonable balance between allowing Participants to make decisions and enabling interested non-Participant stakeholders to observe and comment on those decisions.” Nw. Power Pool, 182 FERC ¶ 61,063, 61,519 (2023). FERC stressed the importance of adequate “openness and inclusiveness” in the governance process. Id.
Given this, RNW also appreciates RAPC’s attempt to problem-solve and identify a path forward that reflects the priority afforded to interregional transmission by the PRC while still making progress on Task Forces necessary to allow participants to meet their FS obligations and remain in the program. However, we note that the draft Task Force Schedule currently reflects an approach developed by RAPC. In the spirit of WRAP’s FERC-approved governance structure, we encourage WPP and the PRC to consider adopting the clarifications set forth in our comments above and NWE’s comments in order to more fully reflect the interests of both participants and non-participants.