01. Please supply any comments related to Appendix A - FS Demonstration Attestation (pg. 18).

Thank you for the opportunity to comment. Bonneville greatly appreciates the continued work by WPP and WRAP members to create greater clarity regarding WRAP structure and operations. Bonneville recommends ending the attestation language at ‘...following due inquiry.’ and deleting all edits. Bonneville understands what is being attempted to clarify with this language, that the loads submitted on a single workbook can be served by the set of resources submitted on the same workbook. We believe that the first half of the language meets this requirement. The second half, the edits, could create problems for Bonneville to meet this attestation regarding some of our resources. In Bonneville’s case, we have loads spread throughout the Mid-C region and across the northern portion of the SWEDE region. We develop a strategy to serve these loads with the resources we have (both federal resources and individual customer resources). Some of these resources serve the total retail load of a specific subset of load and are not located in a manner, either geographically or through transmission interconnectivity, that enables them to be considered capable of serving any of Bonneville’s load in a particular region. In addition to its potential incompatibility with the aforementioned resources, the attestation edits do not appear necessary. The first half already clarifies the intent of what is submitted. The Forward Showing submittal already requires that participants submit transmission from specific resource to load. Additional specification (or a repeat of this requirement) in the attestation is not required.

General Comment