Shell Energy North America (US), L.P and Calpine Energy Solutions, as joint-ESPs submit these comments as WRAP’s only non-BAA competitive energy service providers.  A few foundational matters to consider:

-Participants should discuss and WPP should clarify what are potential reliability implications, rights, and obligations for the Bulk Electric System as a whole and for individual customer loads which are excluded during times of sharing events or supply scarcity. 

-Given SPP Markets+ requires market participants (within a M+ BAA) to meet the WRAP standards, does this make WRAP participation effectively involuntary?  If not, how does WPP plant to accommodate loads which plan to exclude themselves from the program? 

PGE appreciates the opportunity to review and provide suggestions to BPM 103. 

Bonneville appreciates the opportunity to comment on this BPM

SRP is encouraged by the WPP’s ongoing efforts in the developing of WRAP BPMs and has provided comments on relevant sections within this BPM.

An understanding of future load growth projections is critical for the Western Resource Adequacy Program to support resource adequacy. Continuing participant discussion and BPM 103 refinement will provide sufficient certainty that the Western Resource Adequacy Program is realistically assessing and meeting regional needs.

No additional comments at this time.

AWEC appreciates the opportunity to offer comments on BPM 103. AWEC’s membership includes large industrial end users of electricity who are served by investor-owned utilities, customers of Bonneville Power Administration (i.e. public power), and in some cases, by third-parties via direct access programs. The particular circumstances and needs of each AWEC member are unique, and for that reason, AWEC’s interest in providing these comments is to ensure that WRAP’s load exclusion provisions are clear and provide end-use customers with the ability to make cost-effective resource adequacy decisions that fit their specific business needs. In the development of these comments, AWEC discussed its impressions and concerns with BPA.

No further comments.

Tacoma appreciates the opportunity to comment on BPM 103, as well as WPP’s responsiveness to and engagement with participants.