01. Please supply any comments on the draft Task Force Schedule found in Figure 5 (Schedule III)

AWEC finds that the Task Force Schedule is appropriate and in particular supports inclusion of concepts AWS/PAC - 14/19 (Data Center/Large Loads) in the 2026 Draft Workplan beginning July 2026. Given the growth of large loads in utility service territories who are participating or plan to participate in WRAP, addressing the appropriate treatment of these large loads is both critical and timely. WRAP participants are making decisions today on resources necessary to meet capacity requirements, and any further delay in addressing the appropriate treatment of non-conforming loads only risks potential over-procurement of resources to the detriment of ultimate ratepayers who will be responsible for these costs.

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

Consistent with AWEC’s response to Question 1, consideration of changes necessary to address the unique nature of non-conforming loads is necessary well in advance of the March 31, 2027 Forward Showing Deadline because resource acquisitions will need to be made well in advance of this deadline in order for a Participant to meet Forward Showing obligations. Over procurement of capacity and/or the failure to recognize the resource adequacy benefits that some non-conforming loads offer will serve to unnecessarily increase costs to retail consumers and may chill retail customer investment in, and reliance on, co-located and/or behind-the-meter resources. Because utilities and their end-use consumers are making resource procurement decisions now, time is of the essence to address WRAP’s treatment of non-conforming loads.

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

Regarding 2025-CRF-015, AWEC supports Amazon’s requests for clear requirements on load exclusion, including how that standard applies for loads with dedicated backup generation or energy storage systems. AWEC agrees that ensuring the option of load exclusion for loads with dedicated backup generation or energy storage systems will serve to promote reliability both now and in the future. Regarding 2025-CRF-019, AWEC supports PacifiCorp’s proposal to consider the appropriateness of separate treatment for large non-conforming loads, including whether such loads should be assessed an alternative planning reserve margin given their lack of (or lower) contribution to system peak. AWEC also supports exploration of options to exclude of loads with curtailment provisions from a Participant’s Forward Showing as well as options to adjust Forward Showing requirements for loads with co-located resources, including behind-the-meter resources, by treating them as demand response or excluding them from a Participant’s Forward Showing.

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

The Alliance of Western Energy Consumers (“AWEC”) is a trade organization whose members include many of the Pacific Northwest’s largest employers and consumers of electricity and natural gas.  AWEC’s members are responsible for providing tens of thousands of highly paid, technical, family-wage jobs across a broad range of industry sectors such as agriculture, aeronautics, air products, metals, pulp and paper, and more.  As such, AWEC’s members provide significant economic benefits to the communities in which they are located.  Many of AWEC’s members’ host utilities are committed to going binding in Winter 2027 or are themselves customers of Bonneville Power Administration who will participate on their behalf.  As such, AWEC’s members are retail consumers who bear the costs and will receive the benefits of WRAP participation.  AWEC supports a robust resource adequacy program to ensure reliability in the Pacific Northwest and beyond, particularly given the evolving energy landscape. AWEC is also a proponent of ensuring that resource procurement, and ultimately cost allocation, are driven by the principle of cost causation and preserving customer choice when doing so will result in efficient rates and reliable service.