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

Salt River Project (SRP) appreciates the time invested by Task Force participants on this proposal and the intent to set the FSPRM further in advance to improve planning certainty. SRP also appreciates that the Task Force explored tradeoffs between planning certainty and reliability risk, and we recognize that any proposed change must balance these two considerations. SRP also recognizes that setting a binding FSPRM five (5) or more years ahead may create misalignments with other key program drivers that are determined closer to the binding season, such as ELCC results. Mismatches in these key determinants of program requirements and QCC could lead to the program being more or less reliable than its intended target (0.1 LOLE per season). While Participants may find this tradeoff acceptable, SRP would advocate for steps that could reduce some of the misalignment, including a potential “no greater than” treatment that would allow the Program Operator to lower the PRM requirement within the 5-year window if additional Participants join the program or if a Participant adds transmission that improves regional reliability. While acknowledging that the proposed change provides an incremental improvement in certainty for Participant planning purposes, SRP is not convinced that full actionable planning certainty will result from locking in the PRM 5 years in advance in isolation. Future loads will remain significantly uncertain on a 5-year ahead basis and ELCC values will continue to be calculated 2 years in advance. Exploration of these three planning elements in concert is needed to achieve the desired level of planning certainty.

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

SRP understands the goal to refine the Winter Binding Season to better match the time when reliability risks are the highest. As described in SRP’s response to Item 3, SRP is more concerned with modifying the duration of the Winter Binding Season when this change is combined with the described prescriptive definition of risk carried in shoulder months. SRP is concerned with the proposed shift from a large share of winter risk into a relatively small number of days, particularly in November.

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

SRP is concerned that prescriptively assigning higher allowable risk in the shoulder months will result in higher capacity requirements in the peak months of each season. SRP finds that the high level of assigned per-day risk for shoulder months with reduced days in the binding season creates a condition where shoulder month obligations will be significantly reduced at the expense of peak months. By way of example, if the last 11 days in November are indeed a reliability risk, the application of allowed per-day risk at a higher level than peak months will likely obscure this reliability concern behind lower-than-justified capacity requirements. While SRP would otherwise be supportive of the shortened Winter Binding Season, SRP does not believe that the redefined season duration is consistent with the prescribed risk allocation to November. Rather than a prescriptive assignment of risk to each month, SRP would advocate for the WRAP Program Operator to retain existing professional autonomy to iteratively allocate risk based on initial simulations in a way that balances Participant capacity requirements across the season. The WRAP Program Operator’s ability to balance monthly obligations within each season would be stronger with seasonal modeling (including seasonal capacity value for resources), but SRP would still advocate for removing prescriptive monthly risk assignment from the proposal.

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

SRP appreciates the WPP and Task Force providing clarification on whether there is a path to change the FSPRM after it is established. Additionally, the proposal acknowledges several key risks, including the potential for conditions to change after the FSPRM is set, meaning the LOLE study could include participants that later enter/withdraw and materially change the participant mix before a binding season. SRP also understands that the Task Force did not reach consensus on a solution for such circumstances, however the PRC and RAPC would not be precluded from considering circumstances and making a decision to address them through WRAP’s governance process. SRP further appreciates the WPP for sharing that this proposal to extend the FSPRM timeline is implemented through BPMs and not the Tariff. Therefore, if there should be a situation where circumstances materially change after FSPRM is set, participants will have a path to submit an NTFP to change the BPMs to allow an out-of-cycle FSPRM update. SRP appreciates this flexibility and recommends the proposal document this path.

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

SRP appreciates the effort by the Task Force, WPP, and WRAP program operator to improve the PRM framework and strengthen WRAP. SRP is committed to being a constructive participant and supports continued work to improve certainty within the program. SRP’s comments and feedback are intended to help ensure the program is durable and credible across subregions.