City Light suggests WRAP reconsider requiring non-participant entities to sign the JCAF.

City Light suggests that Section 1 Seller’s Transmission Attestation for both Participants and Non-Participants is both unnecessary and not inclusive of possible resource contract arrangements. It does not include options for recognizing resource contracts where the seller can provide resources from multiple sources.

City Light believes that the Non-WRAP Participant Seller Attestation is unnecessary and unlikely to be signed by multiple entities. Entities that are Balancing Authorities have regulatory obligations. Those entities are unlikely to attest to committing to meet commercial obligations over those obligations.

In the transaction type table, need the ability to enter hours of delivery.

In Contracted Capacity Firm Delivery Point box in transaction type: Need to include a separate box for busbar deliveries – which does not require seller attestation of transmission.   

For the Seller’s Transmission Attestation for both Participants and Non-Participants: If the seller is not providing transmission, the seller should not be obligated to sign this attestation.

Powerex notes in BPM 106 Table 2, a JCAF between a Participant seller and a Non-Participant buyer needs to be signed by the Participant. However, in the JCAF Section 1, it states both the buyer and seller need to sign Section 1. We suggest that the requirement to co-sign Section 1 be modified to align with BPM 106. 

Also, Powerex highlights a correction that may be required to the Seller’s Transmission Attestation. The final part of the attestation should read “network integration transmission service rights”. 

Since the attestation that is required is now maintained in BPM 106, we would recommend updating the paragraph in Section 1 to reflect the Appendix and the applicable BPM for the attestation.

An improvement for the WRAP Participant check box could be a drop down in the seller field with all Participants listed where someone could select the counterparty and then since it is all WRAP Participants listed the checkbox can default from the list as to if they are a WRAP Participant or not.

Should the generic attestation around the information provided above being accurate and complete be located after the next two attestations that are listed? We also would highlight the same comment submitted on Appendix A of BPM 106 surrounding the use of NITS for a seller. Also, the JCAF should be edited to match the title of Appendix B in BPM 106.