WPP

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

City Light has no comments regarding this section.

02: Please supply any comments related to the Contracts Eligible for QCC value section (3).

City Light has no comments regarding this section.

03: Please supply any comments related to the Contracts Eligible for QCC value - Resource-Specific Capacity Agreements section (3.1).

City Light recommends that Resource Specific Capacity Agreements section contain language allowing for agreements where entities have contractually obligations to provide firm energy amounts with environmental attributes regardless of the performance of the resource. In these cases, the QCC of the Resource Specific Capacity Agreements would be the contracted firm energy delivery amount.

04: Please supply any comments related to the Contracts Eligible for QCC value - System Sale section (3.2).

City Light suggest that it is unreasonable to require a JCAF or acknowledgement mechanism by both the participant buyer and the non-participant seller of system sales. WRAP procedures and policies are obligations of Participants.

Section 3.2.1 Participant Buyer – Non-Participant Seller

City Light suggests that requiring a yearly attestation after the first JCAF for long term sales between participants is onerous, unnecessary, and burdensome.

3.2.2 Participant Buyer – Non-Participant Seller

3.3.3 Non-Participant Buyer – Participant Seller

City Light suggests that requirements over and above listing system sales to non-participants in the FS workbook are onerous, unnecessary, and burdensome to participants.

05: Please supply any comments related to the Joint Contract Accreditation Forms section (4).

City Light suggest that WRAP policies and obligations are only subject to Participants. Requiring Participants to obtain legal signatory approval by other contract parties is onerous, unnecessary, and burdensome to Participants.