01: Please supply any comments related to section 1.

Since the attestation that is required is now maintained in BPM 106, we would recommend updating the paragraph in Section 1 to reflect the Appendix and the applicable BPM for the attestation.

An improvement for the WRAP Participant check box could be a drop down in the seller field with all Participants listed where someone could select the counterparty and then since it is all WRAP Participants listed the checkbox can default from the list as to if they are a WRAP Participant or not.

Should the generic attestation around the information provided above being accurate and complete be located after the next two attestations that are listed? We also would highlight the same comment submitted on Appendix A of BPM 106 surrounding the use of NITS for a seller. Also, the JCAF should be edited to match the title of Appendix B in BPM 106.

02: Please supply any comments related to section 2.

Documentation Supporting Accreditation box is not aligning with the language in BPM 105, “Resources owned and operated by entities that are not Participants and contracted to Participants with resource specific contracts (i.e., not System Sales or block contracts) must be registered with the Program Operator and provide the necessary data in order for Participants to claim the full QCC from these resources toward their FS Capacity Requirements.” Can this box be better worded to reflect the use of the Contract Accreditation Worksheet that we think is the goal? A system-sale can use the Contract Accreditation Worksheet so we are not sure why only resource-specific is mentioned here.

The “contract provided” is not optional if the transaction is a RA Transfer according to BPM 106. This field should be updated to reflect that and/or the transaction type “RA Transfer” should be removed since a JCAF is not required for that in BPM 106 as currently written.

General Comment

No comment at this time.