Bonneville appreciates the opportunity to provide comment. As stated above, Bonneville is concerned that these edits will have unintended consequences with other parts of the Operations program.  Creating definitions under BPM 209, and specifically tying them to the Energy Delivery Failure Charge and possible waivers, could create ripple effects into other OPS program areas.  Bonneville has concerns regarding these proposed changes because the program has been built around an expectation that once a participant receives a holdback notification and ultimately an energy deployment notification, there is a large degree of discretion given as to how those deliveries are completed.  While not the intention of the program, this could mean that delivers are made from non-WRAP eligible resource or across non-firm transmission, but in the end the energy delivery is made, and the reliability of the WRAP footprints are maintained.  Tightening these definitions under the waiver process seems to undermine this deference regarding delivery and needs further review. Bonneville is unsure if tightening these definitions increases the probability that the energy deliveries are made when called upon or could unintentionally create a loophole for entities utilizing a waiver to get out of an energy delivery, when the sharing calculation says such a delivery is possible.