01: Please supply any comments related to section 1.

City Light suggests WRAP reconsider requiring non-participant entities to sign the JCAF.

City Light suggests that Section 1 Seller’s Transmission Attestation for both Participants and Non-Participants is both unnecessary and not inclusive of possible resource contract arrangements. It does not include options for recognizing resource contracts where the seller can provide resources from multiple sources.

City Light believes that the Non-WRAP Participant Seller Attestation is unnecessary and unlikely to be signed by multiple entities. Entities that are Balancing Authorities have regulatory obligations. Those entities are unlikely to attest to committing to meet commercial obligations over those obligations.

02: Please supply any comments related to section 2.

City Light suggests that the Contracted Capacity Firm Delivery Point does not include options for recognizing resource contracts where the seller can provide resources from either multiple sources or through general market activity.

General Comment

City Light recommends that WRAP consider that participant attestations and forward showing reporting should be sufficient documentation for the program.