There have been discussions in the past for JCAF requirements relating to PURPA and other small contracts. It would be helpful to clearly list in a table format all contract types that need and don't need a JCAF based on various attributes.

We believe that BPM 106 should also cover information related the risk of over/under performance assumed by purchaser and contingency reserve obligation assumed by purchaser that was added to the FS workbook and JCAF.

PacifiCorp understands and supports the need to seek assurances capacity from outside the WRAP footprint will be available when needed. PacifiCorp supports the creation of a standard document, such as the JCAF, which can become commonplace and recognizable within the industry.

However, PacifiCorp views the requirement of a JCAF as being too broadly applied in this BPM.  It is PacifiCorp’s understanding that the JCAF was intended to create a method to ensure contracts for unspecified capacity were backed by firm capacity before being included in the Participants FS Submittal.  However, this BPM has extended the JCAF requirements to resource specific contracts and contracts between participants both of which the Program Operator has the ability to confirm without creating both a significant administrative burden for Participants, and potentially undermining the purpose of WRAP.

NV Energy appreciates the opportunity to comment on BPM 106 and offers additional general comments to gain additional understanding about the types of contracts that will qualify towards meeting a participant Forward Showing requirements. NV Energy believes the following questions should be addressed somewhere in this BPM:

1. How many hours should be procured to qualify towards meeting the Forward Showing requirement? For instance, does a participant need to procure supply for all hours of the month or do they only need to procure supply needed during the capacity critical hours? Additionally, would a super peak product qualify towards meeting the Forward Showing requirement at a percentage of the contracted amount if not all the capacity critical hours were procured?
2. Can the contract state that the resource may not be needed during times of low loads when excess cheap supply exists or will the resource be required to be dispatched for all hours of the month to be applied towards the Forward Showing? NV Energy argues that a contract should be allowed to not be needed when loads are low and excess cheap supply exists otherwise this capacity would require participants to over procure during low load periods.  

Thank you for the opportunity to comment

City Light suggest that BPM 106 - Qualifying Contracts cannot be approved as a business practice by the RAPC until appropriate WRAP Tariff changes have been thoroughly discussed and approved.

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.

As a general comment, the BPM should be consistent with the tariff unless an explicit change to the tariff has been identified as necessary.

Thank you for the opportunity to provide comments.