01: Please supply any comments related to section 1.

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”. 

02: Please supply any comments related to section 2.

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...”) 

General Comment