In this section it says Firm capacity sales made by a Participant to parties outside the WRAP must be on the FS Submittal, does this preclude an entity from selling capacity products after the FS Submittal is complete because they would not be able to comply with including it in the FS Submittal if not transacted beforehand? It also says a JCAF is not required for sales to non-WRAP participants, but Table 1 contradicts that and says it is required the first time.

Contrary to the tables in section 4, which describe the requirement of a JCAF for Participant sales to Non-Participants, paragraph two of Section 5 states:

“Firm capacity sales by a Participant to parties outside the WRAP Region must be declared and included as a capacity obligation in the Participant’s FS Submittal; a JCAF is not required for firm capacity sales to non-WRAP participants”

City Light has no further comments regarding this section.

SRP appreciates the detail provided on the methodology for Calculating Net Contract QCC. To further assist participants, SRP recommends the WPP provide a detailed example calculation, showcasing the step-by-step process and how various contract types are handled within this framework.

To confirm the submission and handling of sensitive information required for QCC calculations, SRP recommends the BPM reference section 10 (Treatment of Confidential and Commercially Sensitive Information of Participants) of the Tariff.