Bonneville opposes 2024-CFR-009 as a Non-Task Force Proposal, and requests that this proposal go through the PRC task force. Bonneville believes there could be un-intended consequences associated with including definitions pertaining to the FS program into the Operations program waiver process. These un-intended consequences are likely to limit flexibility in the operational window and increase the cost of participation. Un-intended consequences include, but are not limited to: • Changing how energy delivery can be met operationally • Definition changes could create a path for waiver of delivery failure because a firm transmission right was curtailed while non-firm was still available. • Failure to deliver charges already incentivize entities to use firm transmission whenever possible and to ensure delivery is made even when using non-firm transmission. A stronger definition could cause entities to hold an excess amount of firm transmission, which in turn limits the amount of transmission available for others, driving up the cost of program compliance.