Comment Submission

Bonneville appreciates the opportunity to comment and wholly supports the streamline changes to the JCAF process, as well as the exploration of an Embedded Load Agreement.

Bonneville requests clarity on the JCAF proposal. The edits to BPM 106 only make clear no signature is required. If no JCAF will be needed at all in this situation, please make that explicit.

The second part of the NTFP (Embedded Load Agreement) should be split into its own NTFP. This is likely an issue that will require discussion and iterative commenting. It does not seem appropriate to package this concept with the JCAF modification that is very straightforward. Bonneville would like further clarification on what WPP sees as the application for an Embedded Load Agreement. High-level scenarios where this may be applicable would be helpful. Bonneville also requests clarity on how this differs from the Agent structure that is already present in WRAP.

Bonneville would also like clarification on whether the LRE would register with WRAP only the load and resources within the scope of its relationship with its customer (for which it is not the LRE), or if the LRE would be obliged to report all load and resources of the customer. Additionally, Bonneville requests that the sponsor of the NTFP state that registering Embedded Load in the FS Program would not impact a WRAP Participant’s Operating Program requirements.

As WRAP implementation moves closer to binding operations, and many WRAP participants advance in DAM implementation, Bonneville sees the value in creating a path where a WRAP Participant can register load for which it is not the LRE with WRAP that would otherwise not be assigned to a WRAP Participant and therefore be potentially ineligible for DAM participation. We look forward to discussing this issue further with WPP staff and other WRAP participants.