Documentation Supporting Accreditation box is not aligning with the language in BPM 105, “Resources owned and operated by entities that are not Participants and contracted to Participants with resource specific contracts (i.e., not System Sales or block contracts) must be registered with the Program Operator and provide the necessary data in order for Participants to claim the full QCC from these resources toward their FS Capacity Requirements.” Can this box be better worded to reflect the use of the Contract Accreditation Worksheet that we think is the goal? A system-sale can use the Contract Accreditation Worksheet so we are not sure why only resource-specific is mentioned here.

The “contract provided” is not optional if the transaction is a RA Transfer according to BPM 106. This field should be updated to reflect that and/or the transaction type “RA Transfer” should be removed since a JCAF is not required for that in BPM 106 as currently written.

Powerex recommends that the language in  the Non-WRAP Participant Seller Attestation language be modified to more closely match that of the language in section 16.2.6.1 of the tariff (“....an assurance that the capacity is not used for another entity’s resource adequacy requirements, an assurance that the seller will not fail to deliver in order to meet other supply obligations...”) 

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.   

City Light suggests that the Contracted Capacity Firm Delivery Point does not include options for recognizing resource contracts where the seller can provide resources from either multiple sources or through general market activity.