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

No response submitted.

02: Please supply any comments related to the Application and Registration section (2).

Overall comment on Table 1 - dates indicated in table for using participant submitted Advanced Assessment data for QCC’s are wrong.  Section 4.1.1 notes it correctly as the first 2 seasons use class average numbers.

Comment on Table 1 - First Summer FS Deadline: Does this FS come with binding Cone Charges/Capacity Chargers? We want to encourage entities to join, this feels like it forces a new participant to know beyond a reasonable doubt that they will pass Forward Showing before they Execute a WRAPA - no season to verify that they have done everything correctly!

Comment on Table 1 - First Binding  Operations Season: Concerned over this first Operation period being a binding season - and the potential for bad data (not production quality). By this season being binding a new participant doesn’t have a period to see OPS in process and understand how their data fits and work out bugs.  Maybe something even as simple as June is a voluntary month and July-Sept is binding would help address this concern.

Comment on Table 1 - Summer FS Deadline: “this showing will be the first using QCC values for resources Participant turned in at its first Advance Assessment” – Saying that the Summer submittal in year 1 uses QCC values from the participants first Advanced Assessment does not give the 1 year notice on those values to the participant, the participant’s first Advanced Assessment submittal only happened in 8 months before. These values would still be class average, or be used with less than 1 years notice! The QCC’s used during the first October would have been published 1 year in advance of FS submittal deadline that would be the October immediately after they became a participant, and before they submitted there first Advanced Assessment in March.  Section 4.1.1 reflects this timing correctly.

Comment on Table 2 - First Summer FS Deadline: QCC’s and PRMs need to be published a minimum of one year in advance (October 23). Use class average.

Comment on Table 2 - Deadline for First Advanced Assessment data submittal: Table 2 should reflect all lines of table 1 based on a specific year.

Comment on Table 2 - Summer FS Deadline: This jumped forward to 2027? October 31 2025 would still be using calculated QCC’s and PRMs from the 2023 Advanced Assessment (before they became a participant). Need to use class average.

03: Please supply any comments related to the Application and Registration - Election of Transition Binding Seasons section (2.1).

No response submitted.

04: Please supply any comments related to the Application and Registration - Registration of Resources section (2.2).

No response submitted.

05: Please supply any comments related to the Application and Registration - Cash Working Capital Support Charge section (2.3).

No response submitted.

06: Please supply any comments related to the Application and Registration - Membership in WPP section (2.4).

No response submitted.

07: Please supply any comments related to the WRAP Administration section (3).

No response submitted.

08: Please supply any comments related to the WRAP Administration - Committee Involvement section (3.1).

No response submitted.

09: Please supply any comments related to the WRAP Administration - Participant Resources section (3.2).

No response submitted.

10: Please supply any comments related to the WRAP Program Implementation section (4).

No response submitted.

11: Please supply any comments related to the WRAP Program Implementation - Forward Showing Program section (4.1).

Comment on 4.1.1 Approximating QCCs – “New Participants will complete a limited Data Request”: Is this defined? How will this be used by WRAP? Based on these dates a new participant would basically have to have this ready for submittal as they joined..  How do we plan to use it?  Why is it important or necessary to have this off a normal schedule?

12: Please supply any comments related to the WRAP Program Implementation - Operations Program section (4.2).

“Participants shall complete registration and testing in advance of participation…”: Testing can be completed in isolation as the individual entity not have data regarding a period of full participation with all participants. Are we allowing accurate time for new participants to understand Operations and the tools?  BPA would suggest a non-binding month for those new participants as they start, such as June - being non-binding/voluntary participation and July starts full binding participation.

General Comment

BPA appreciates the opportunity to provide comment.