01: Please supply any comments related to section 1.

No response submitted.

02: Please supply any comments related to section 2.

No response submitted.

General Comment

Shell Energy North America (US), L.P. ("Shell Energy") has a keen interest in JCAFs as many of Shell Energy's contracts for RA resources are with Independent Power Producers ("IPPs") which are not WRAP participants themselves.  Shell Energy is concerned some IPPs may not elect to sign a JCAF with the understanding the selling IPP could be implicated in the WRAP program in some manner and subject to uncertainty whether the contracted resource is indeed “RA quality” under WRAP.  Further, should a WRAP participant not secure a JCAF form, the participant would not be able to utilize this contracted capacity to meet the FS obligation, even if the WRAP participant held rights to all products from a hypothetical generating resource.  

Hence, Shell Energy believes there is a demonstrable need, before the program goes fully binding, to create a petition process whereby a WRAP participant may appeal directly to the WPP Board for an exception to the JCAF requirement or some alternative compliance method.  It is reasonable that the WRAP participant’s unredacted contract be submitted concurrently with the petition the Board which could then discuss in executive session and subject to confidentiality provisions.  

Further, WPP should create a Q&A document or generic reference guide as to the qualifications a WRAP RA-qualified product may include.