COMMENT FOR BPM 304 - Amendments to Schedule 1 and WRAP Agreement

Submitted Feb. 2, 2024, 11:42 a.m.



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

No response submitted.

02: Please supply any comments related to the Amendment Requests section (2).

No response submitted.

03: Please supply any comments related to the RAPC Amendment Review section (3).

No response submitted.

04: Please supply any comments related to the RAPC Endorsement section (4).

No response submitted.

05: Please supply any comments related to the Board of Directors Review section (5),

As stated in the BPM:

4.  RAPC Endorsement

                3)  The RAPC votes to reject the proposed Amendment – in which case the Amendment sponsor may decide to allow the proposal to terminate, may provide changes to the Amendment to be reconsidered by the RAPC, or may request consideration by the Board.

Then later stated in the BPM:

5.  Board of Directors Review

  • Have been rejected or not acted upon by the RAPC but have been requested for review by a Participant, the Program Operator, or the Program Administrator, a Board member, or the Board itself.

Two questions: 

1)  Should the Board of Directors bulletpoint also include “requested consideration from an Amendment sponsor” or is this inferred by “requested for review by a participant”? 

2)  By including “having been rejected or not acted upon by the RAPC but have been requested for review by a Participant…” does this circumvent the need for review by the RAPC and the requirement of a 75% affirmative vote in both the House and Senate?

General Comment

PNM appreciates the opportunity to comment on BPM 304.