SRP supports the revised attestation language in Appendix A of BPM 108. The clarification aligns with SRP’s understanding that the attestation is intended to confirm that the submitted resources and contracts can be used to serve the loads included in a participant’s same Forward Showing submission. The revised language improves clarity without changing the intent or function of the attestation.

Seattle City Light supports the revised language in WRAP BPM 108 Appendix A – FS Demonstration Attestation. These revisions improve conceptual clarity and promote greater consistency throughout the WRAP program. By clearly delineating that the attestation is about resource deliverability, the revision aligns the document with its intended purpose and removes any potential confusion. City Light also appreciates the effort to strengthen alignment and transparency across the program components. This is a positive, thoughtful improvement that benefits all WRAP participants and stakeholders.

Thank you for the opportunity to comment. Bonneville greatly appreciates the continued work by WPP and WRAP members to create greater clarity regarding WRAP structure and operations. Bonneville recommends ending the attestation language at ‘...following due inquiry.’ and deleting all edits. Bonneville understands what is being attempted to clarify with this language, that the loads submitted on a single workbook can be served by the set of resources submitted on the same workbook. We believe that the first half of the language meets this requirement. The second half, the edits, could create problems for Bonneville to meet this attestation regarding some of our resources. In Bonneville’s case, we have loads spread throughout the Mid-C region and across the northern portion of the SWEDE region. We develop a strategy to serve these loads with the resources we have (both federal resources and individual customer resources). Some of these resources serve the total retail load of a specific subset of load and are not located in a manner, either geographically or through transmission interconnectivity, that enables them to be considered capable of serving any of Bonneville’s load in a particular region. In addition to its potential incompatibility with the aforementioned resources, the attestation edits do not appear necessary. The first half already clarifies the intent of what is submitted. The Forward Showing submittal already requires that participants submit transmission from specific resource to load. Additional specification (or a repeat of this requirement) in the attestation is not required.

Idaho Power appreciates WPP’s efforts to develop revisions to this attestation to clarify the intent. Despite participants’ best efforts in the original drafting, the language is ambiguous as written and could be interpreted as an attestation that the participant believes that resources are sufficient to serve load and pass the Forward Showing Submittal requirements, which may not be accurate in all cases. The intent of the language was to confirm deliverability of resources to load(s), not to attest that the Forward Showing Submittal has been passed. As such, Idaho Power supports the proposed revisions as they clarify that intent.