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

No response submitted.

02: Please supply any comments related to the Amendment Requests section (2).

No response submitted.

03: Please supply any comments related to the RAPC Amendment Review section (3).

No response submitted.

04: Please supply any comments related to the RAPC Endorsement section (4).

No response submitted.

05: Please supply any comments related to the Board of Directors Review section (5),

Section 5 states that “the Board will receive all Proposals...for review and consideration” including proposals that have been rejected or not acted upon by the RAPC, which seems to suggest that ALL Proposals, including those rejected by the RAPC, will be reviewed by the Board. However, later in section 5 it is stated that “Whether to consider a previously rejected Amendment is solely within the Board’s discretion.”

Currently, there are four actions the Board may take on a proposed Amendment. Powerex requests that the language be clarified regarding whether a previously rejected Proposal must be reviewed by the Board.  If the Board does have the discretion to not take any action or not review a proposal that should be listed as a new action #5.

Also, in the second enumerated action that the Board can take on a proposed amendment, it is described how “...WPP will make a Section 205 filing to amend the WRAPA and/or Schedule 1 in the Tariff”, if the RAPC takes no action within two weeks of the Board voting to approve a proposed Amendment with changes. Powerex suggests that the RAPC should be given 30 days to act on an Amendment approved with changes, to ensure the RAPC has sufficient time to review and discuss the changes prior to the FPA Section 205 filing.

General Comment