Powerex notes there is an incorrect reference to Section 43.2, which should instead be Section 3.2

The label for Table 1 is at the top where the label for Table 2 is at the bottom, we’d recommend moving the label for Table 2 to the top for consistency.

In table 1 under the less than 100% off take it requires re-submission for each Forward Showing, which seems unnecessary. If this is a long-term PPA for a portion of a resource that portion of the resource will not change from one Forward Showing to the next, can we utilize the JCAF once to reflect the full term of the contract, then attest each Forward Showing Year that it hasn’t changed?

PacifiCorp does not see a difference between “100% off take” and “100% off take and must take”, and does not view a JCAF as necessary for either category. In addition, resource-specific contracts for less than 100% off-take of a resource registered in the WRAP should not require a JCAF. The resources included in the Forward Showing are attested to by a company senior official, and the Participant bears the risk of non-performance. PacifiCorp views the requirement of a JCAF for every capacity agreement as a significant administrative burden with little incremental benefit to the program.

NV Energy does not understand the difference between the resource specific delineation in Table 1 of the 100% off take or must take contracts. If a resource is contracted 100% to a participant, then that resource should be credited towards the participants Forward Showing without the requirement to fill out a JCAF.  A contract that includes a provision where the participant may decide not to take all of the energy would likely occur during instances of oversupply conditions and should not hinder the reliability of this program.  The requirement to sign a JCAF by both the participant and the seller of a resource that is registered in the program and 100% contracted to that participant is excessive and administratively burdensome considering the participant has to attest to all information supplied in each Forward Showing. Therefore, NV Energy does not support the requirement to fill out a JCAF for a resource that is 100% contracted to supply the participant buyer.  Furthermore, NV Energy does not support the requirement to submit a JCAF for each resource specific contract that is less than 100% off take for each Forward Showing season. Resources that are registered with the program should not have to go through the extra burden of submitting a JCAF.

Section 4 also requires a participant to provide a signed JCAF for sales to non-participants.  NV Energy does not understand the reasoning for this. The program requires the participant to list all purchases and sales in the Forward Showing with an attestation, therefore, it is not clear why an additional JCAF form is required.  NV Energy does not support this requirement when a participant sells to a non-participant.  

Again, an attestation does not seem necessary if parties have already attest to the JCAF that contains the terms.

City Light suggest that WRAP policies and obligations are only subject to Participants. Requiring Participants to obtain legal signatory approval by other contract parties is onerous, unnecessary, and burdensome to Participants.

SRP recommends the WPP include a sample completed JCAF or a detailed walkthrough of the form filling process. This has the potential to assist participants in accurately completing and submitting these forms.

Further, SRP encourages the WPP to provide explicit guidance in regards to the actions a participant should take and the implications of being unable to obtain a signature on the JCAF. This may provide clarity to participants on the process and potential consequences.

Table 1 reflects that a JCAF must be provided the first time a contract is claimed between a Participant Seller and a Non-participant Buyer. This is contradictory to the requirement specified in Section 5, which states that “a JCAF is not required for firm capacity sales to non-WRAP participants.”

Idaho Power believes the requirement to provide a JCAF, signed by the Participant, for sales to non-participant buyers is excessive. Participants are required to list all sales in their Forward Showing and provide an accompanying attestation. This seems sufficient, and the additional requirement for a JCAF is not necessary.