Bonneville appreciates the opportunity to comment and wholly supports the streamline changes to the JCAF process, as well as the exploration of an Embedded Load Agreement.

Bonneville requests clarity on the JCAF proposal. The edits to BPM 106 only make clear no signature is required. If no JCAF will be needed at all in this situation, please make that explicit.

The second part of the NTFP (Embedded Load Agreement) should be split into its own NTFP. This is likely an issue that will require discussion and iterative commenting. It does not seem appropriate to package this concept with the JCAF modification that is very straightforward. Bonneville would like further clarification on what WPP sees as the application for an Embedded Load Agreement. High-level scenarios where this may be applicable would be helpful. Bonneville also requests clarity on how this differs from the Agent structure that is already present in WRAP.

Bonneville would also like clarification on whether the LRE would register with WRAP only the load and resources within the scope of its relationship with its customer (for which it is not the LRE), or if the LRE would be obliged to report all load and resources of the customer. Additionally, Bonneville requests that the sponsor of the NTFP state that registering Embedded Load in the FS Program would not impact a WRAP Participant’s Operating Program requirements.

As WRAP implementation moves closer to binding operations, and many WRAP participants advance in DAM implementation, Bonneville sees the value in creating a path where a WRAP Participant can register load for which it is not the LRE with WRAP that would otherwise not be assigned to a WRAP Participant and therefore be potentially ineligible for DAM participation. We look forward to discussing this issue further with WPP staff and other WRAP participants.

Puget Sound Energy appreciates the opportunity to comment on this NTFP.  We appreciate the efforts in developing this proposal and express full support.

APS supports the removal of the JCAF requirement for Participant-to-Participant contracts, as it would reduce administrative burden and provide relief to customers who have already demonstrated the accuracy of their information through the Forward Showing Demonstration process.

We would like additional information as in Section 2 Background regarding a JCAF that is required “with the seller to the Embedded Load Customer as described below.” As well as the inclusion of Section 3.3 “Embedded Load Qualifying Contact” as it is listed in the Table of Contents.

The Western Power Trading Forum (WPTF) is a California nonprofit, public benefit corporation dedicated to enhancing competition in Western electric markets while maintaining high levels of system reliability. WPTF supports the development of competitive markets throughout the West and fair rules that facilitate transactions among market participants.  WPTF supports WRAP’s vision of a robust RA program which provides regional benefits and promotes reliability across the interconnection. And WPTF supports the continued development and evolution of WRAP, including its enhanced coordination with Markets+ for operationalizing the program.

WPTF comments on the proposed revisions to BPM 106 (Qualifying Contracts) focus on the need to avoid rules that inadvertently provide what may be seen as a simpler/less burdensome process for load-serving entity (LSE)/Load Responsible Entity (LRE) program participants to attest to contracts for capacity in WRAP, as compared to the process for attesting to contracts with independent generators, marketers, and other RA suppliers. More generally, WPTF is concerned with the trend for western RA programs to treat LSE sellers of RA capacity differently than non-LSE sellers of RA capacity for purposes of program participation and contract verification. And this concern is the primary reason for submitting comments on this BPM change, even though we recognize the resolution to this issue would require changes beyond the scope of this BPM.

The underlying cause of western RA program treating non-LSE sellers of RA capacity differently that LSE-sellers, in many instances, can be traced back to the definition of a Participant. The WRAP Tariff defines a Participant as “A Load Responsible Entity that is a signatory to the WRAPA.” This means that any rules that apply to Participants, or make it easier for Participants to attest to contractual exchanges of capacity with one another, are inherently limited to LREs. And this could result in rules that, inadvertently, create higher bars and/or a different set of rules for non-LRE/LSE sellers of RA capacity to have their capacity accredited and counted under WRAP.

Under the proposed revisions to BPM 106, a Resource-Specific Capacity Agreement or System Sale between two WRAP Participants would no longer require a signed Joint Contract Accreditation Form (JCAF). While WPTF supports reducing unnecessary administrative burden in WRAP, which this change could help achieve, we are concerned that the proposal to ease the burden of counting Participant-to-Participant contracts within WRAP could have the unintended consequence of treating certain types of sellers of RA capacity differently for purposes of having their capacity accredited and able to be used in WRAP. Because of the way WRAP Participants are currently defined, under the proposed modifications to BPM 106, the accreditation process by which contracts can be counted in WRAP without a JCAF would be limited to LREs/LSEs. Enabling LRE program participants to accredit contracted capacity without any additional verification/attestation beyond their existing WRAP requirements, but requiring additional verification (via the JCAF) when the seller is not a program Participant, could be seen  as providing a lighter burden for the accreditation of contracts between LSEs in the program.

We understand that the purpose of the BPM modifications is to eliminate what WRAP Participants see as duplicative administrative steps for counting transactions between Participants in the program, given that Participants are already subject to attestation and registration of capacity via the Forward Showing. And WPTF generally supports eliminating duplicative requirements and reducing administrative burdens. But WPTF also supports a program under which verification requirements or contract review standards can apply equally to all types of sellers. Going forward WPTF hopes that there can be a pathway where all sellers of RA capacity could have an option to avoid the JCAF process by instead becoming a program Participant, though we recognize this would require a change in WRAP’s tariff and is beyond the scope of the proposed changes to BPM 106.  As the program continues to evolve, we urge WRAP to consider whether it would be appropriate to expand the definition of program Participant in a way that might help address this concern and could provide the same pathway to accreditation of contracts to non-LSE sellers of RA.