01: Please supply any comments related to the Introduction, Definitions, or Background sections.

No response submitted.

02: Please supply any comments related to the Reduction in Sharing Calculation section.

No response submitted.

03: Please supply any comments related to the Priorities of Access During the Transition Period When Aggregate Holdback Requirements Are Limited section.

No response submitted.

05: Please supply any comments related to the Access to Voluntarily Offered Capacity section.

Powerex understands from Section 15.1.1 of the WRAP Tariff that during Non-Binding Seasons participants will not be subject to Holdback Requirements.  Powerex suggests that the following language (or language similar) be added to Table 1, Tier Three (Non-Binding Participants), Column 3 (Obligations to WRAP) or be indicated as a footnote to Table 1:

“Not subject to binding WRAP obligations for Operations, including the Holdback Requirement.”

General Comment