01: Please supply any comments related to the final paragraph of the Non-Exclusive List of Potential Waiver Justifications section (7.3) - text in RED.

City Light supports the proposed language stating that waivers will not be granted to participants that make sales beyond their capacity surplus above there FS Capacity Requirement.

02: Please supply any comments related to the Presumptive Waiver for Uncertainty Exceedances section (7.4) - text in RED.

City Light supports the concept of WRAP having a Presumptive Waiver for Uncertainty Exceedances and has no further comment regarding the text in RED.

03: Please supply any additional comments on this BPM.

City Light has no additional comments on this BPM.

General Comment

City Light has no additional general comments.