APS is in complete support of the proposed language as it provides sufficient clarity for non-NERC priority transmission products. APS agrees with the approach taken in this proposal to create a definition of the WRAP Qualifying Transmission that can be referenced throughout the tariff. The flexibility of this approach allows for application to other transmission products that could potentially develop in the future.
Part (iii) reflects the Task Force’s collaboration, and it provides sufficient clarity for non-NERC labeled firm transmission products to be recognized by WRAP.
Oct. 17, 2025, 11:09 a.m.
Bonneville supports the definition of WRAP qualifying transmission. Specifically, Bonneville believes it is appropriate to include transmission priority codes six and seven while also calling out the highest transmission service offered by a transmission service provider.
Bonneville believes that section (iii) provides the necessary clarity for non-NERC priority transmission. This portion of the definition provides framework and reference to the highest priority transmission service offered by a transmission service provider. Section (iii) also makes clear that curtailment of the transmission service should only occur under reliability conditions necessary to maintain transmission system operations. Bonneville believes that this definition provides stakeholders necessary assurance and certainty for WRAP transactions flowing on WRAP qualifying transmission.