01. Do you have any comments on the proposal itself?

Bonneville supports the proposal and the approach (utilizing a defined WRAP Qualifying Transmission) proposed by the task force. Specifically, Bonneville feels it is appropriate to define WRAP Qualifying Transmission and to use it throughout varying WRAP documents. This approach provides clarity to stakeholders as to what transmission types constitute qualifying transmission while ensuring alignment and cohesiveness across multiple WRAP documents. Lastly, this approach affords a simple way to modify “WRAP Qualifying Transmission” in event that it becomes necessary.

02. Do you have any comments on the WRAP Qualifying Transmission definition, including whether the proposed language in part (iii) provides sufficient clarity for non-NERC priority transmission products such as CAISO’s Priority Wheeling Through?

Bonneville supports the definition of WRAP qualifying transmission. Specifically, Bonneville believes it is appropriate to include transmission priority codes six and seven while also calling out the highest transmission service offered by a transmission service provider. Bonneville believes that section (iii) provides the necessary clarity for non-NERC priority transmission. This portion of the definition provides framework and reference to the highest priority transmission service offered by a transmission service provider. Section (iii) also makes clear that curtailment of the transmission service should only occur under reliability conditions necessary to maintain transmission system operations. Bonneville believes that this definition provides stakeholders necessary assurance and certainty for WRAP transactions flowing on WRAP qualifying transmission.

03. Do you have any questions regarding the redlines to the WRAP Tariff?

No, the proposed redline changes are clear and appear to have been made in the appropriate places throughout the document.

04. Do you have any questions regarding the redlines to BPM 103 – Participant Forward Showing Capacity Requirements?

No, the proposed redline changes are clear and appear to have been made in the appropriate places throughout the document.

05. Do you have any questions regarding the redlines to BPM 106 – Qualifying Contracts?

No, the proposed redline changes are clear and appear to have been made in the appropriate places throughout the document.

06. Do you have any questions regarding the redlines to BPM 108 – Forward Showing Submittal Process?

No, the proposed redline changes are clear and appear to have been made in the appropriate places throughout the document.

07. Do you have any questions regarding the redlines to BPM 202 – Participant Sharing Calculation Inputs?

No, the proposed redline changes are clear and appear to have been made in the appropriate places throughout the document

08. Do you have any questions regarding the redlines to BPM 204 – Holdback Requirement?

No, the proposed redline changes are clear and appear to have been made in the appropriate places throughout the document.

09. Do you have any questions regarding the redlines to BPM 209 – Energy Delivery Failure Charge?

No, the proposed redline changes are clear and appear to have been made in the appropriate places throughout the document.

General Comment

In conclusion, Bonneville supports the definition as drafted and thanks the task force for their efforts in bringing clarity to what constitutes WRAP Qualifying Transmission.