01. Please supply any comments on the draft Task Force Schedule found in Figure 3

TEA is in favor of re-prioritizing CONCEPT 02 – EARLIER FS METRICS / MONTHLY VOLATILITY (PRM) from the 2026 Task Force workstream to the to 2025 Task Force workstream. To accommodate this re-prioritization, TEA would be in favor of moving CONCEPT 05 – LOAD GROWTH FACTOR to the 2026 Task Force workstream. Alternatively, depending on the expected go-live of SPP’s Markets+ day-ahead market (M+), work on CONCEPT 01 – DAM OPTIMIZATION as it specifically relates to M+ could potentially be pushed out to the 2026 workstream. TEA’s main driver for this re-prioritization is that the monthly PRM volatility that currently exists in the non-binding program is making it difficult to secure sufficient qualifying capacity to meet program requirements, particularly for shoulder months. Ensuring that TEA is resource adequate is the top concern for TEA and its participating utilities when it comes to participation in the binding program.

02. Please supply any comments on Concepts that could impact a commitment to go Binding or remaining in the WRAP

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 Section 6. Next Steps

No response submitted.

09. Please supply any comments on Appendix A - Change Request Form Compilation

With respect to 2024-CRF-017 / IPC / Monthly PRM Volatility, TEA agrees with the issue description provided by Idaho Power Company. TEA is similarly concerned that the monthly PRMs calculated during this current non-binding phase of the program have exhibited some concerning volatility month-to-month. As with Idaho Power, participating utilities in the TEA LRE have also seen some shoulder season months where the P50 load + monthly PRM significantly exceeds the utility’s own extreme weather load forecasts as well as its own long-term planning load forecasts. TEA also supports the desire for participants to receive forward showing metrics on an earlier timeline as described in change request 2024-CRF-002 / NVE / Earlier Forward Showing Metrics.

10. Please supply any comments on Appendix B - PRC Minutes Dec. 18th, 2024

No response submitted.

11. Please supply any comments on Appendix C - PRC Minutes Jan. 23rd, 2025

No response submitted.

12. Please supply any comments on Appendix D - PRC Minutes Feb. 19th, 2025

No response submitted.

General Comment

The Energy Authority, Inc. (TEA) is a public power-owned, not-for-profit corporation providing utilities with energy scheduling, marketing, and power supply portfolio management services. TEA is currently participating in WRAP as a Load Responsible Entity (LRE) for five Northwest public power utilities in the states of Washington and Oregon (Clark Public Utilities, Cowlitz Public Utility District, Emerald People’s Utility District, Franklin Public Utility District, and Lewis Public Utility District).