PRC Comments / 2026-EP-06 (Rockies FS Deadline)

Comment Submission

Camille C. Idaho Power Company

Submitted Responses

2026-EP-06 (Rockies FS Deadline)

Please supply any comments related to the proposed changes in BPM 101 - Advance Assessment

No response submitted.

Please supply any comments related to the proposed changes in BPM 108 - FS Submittal Process

No response submitted.

Please supply any comments related to the proposed changes in the WRAP Tariff

No response submitted.

General Comment

Idaho Power supports the proposed tariff and BPM changes establishing a process to develop and implement Forward Showing Planning Reserve Margins (FSPRMs) for the new Rockies Subregion. The proposal addresses a practical implementation issue created by the addition of new Colorado participants after the standard WRAP timelines for establishing subregional metrics had passed.

Idaho Power agrees that WRAP should provide a workable path for onboarding new participants and subregions while maintaining the integrity of the resource adequacy framework. Given that there were no Rockies participants when the original deadlines occurred and that FERC denied WPP's waiver request, the proposed tariff revisions represent a reasonable approach to establishing the necessary metrics and enabling participation in the program.

Idaho Power appreciates the efforts of WPP, stakeholders, and SPP to develop the required FSPRMs and supports approval of 2026-EP-06 as proposed.