Comment Submission

We appreciate the inclusion of Embedded Load Qualifying Contracts in the Forward Showing framework. However, the last paragraph of Section 2 indicating that a JCAF is required “with the seller to the Embedded Load Customer as described below” is not described in detail or specifically referenced any further than the mention.  

In the table of contents, there is a Section 3.3 “Embedded Load Qualifying Contact” referenced, but this section does not exist further in the BPM. Additionally in the table of contents this section notes “Error bookmark not defined.” 

APS would appreciate this addition that could better clarify the contract between the embedded load customer and the seller, along with the minor fix in the Table of Contents.

The first sentence in this section incorrectly strikes out the word "tracked."

We appreciate and support the elimination of the JCAF requirements for Participant to Participant contracts.

Given the Embedded Load construct, explicit language in this section would be helpful.

Because the WRAP Participant is not a party to the underlying contract, it would be useful to explicitly state that the JCAF is executed between the seller and the Embedded Load Customer, and that the Participant relies on this JCAF for its or a Forward Showing. This would align existing principles for non-Participant transactions and provide more clarity on contracts between embedded load customers that have recently been defined in this BPM.  

Again APS seeks clarification in ensuring there is clear direction for the scenario where the WRAP Participant is not a party to the underlying contract, it would be useful to explicitly state that the JCAF is executed between the seller and the Embedded Load Customer, and that the Participant relies on this JCAF for its Forward Showing.

APS supports the removal of the JCAF requirement for Participant-to-Participant contracts, as it would reduce administrative burden and provide relief to customers who have already demonstrated the accuracy of their information through the Forward Showing Demonstration process.

We would like additional information as in Section 2 Background regarding a JCAF that is required “with the seller to the Embedded Load Customer as described below.” As well as the inclusion of Section 3.3 “Embedded Load Qualifying Contact” as it is listed in the Table of Contents.