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).

SRP recommends the WPP consider specifying in BPM 304 a minimum comment timeframe for the RAPC to review amendments. The current language is vague and allows flexibility SRP recommends that at a minimum 20-days are identified in BPM 304 for any amendment review. This would enhance predictability and transparency in the amendment review process and allow for clear workload management.

Additionally, SRP supports WPP’s assessment that the comment period may be extended, including beyond SRP’s recommended 20-day minimum timeframe, should the RAPC Chair and Program Administrator determine that the amendment is of increased length, complexity and anticipated of the amendment. Furthermore, SRP recommends all comments received should be available on the WPP website for RAPC review.

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),

SRP appreciates the role of the Board of Directors in the final amendment review and understands that they have ultimate authority over the Tariff and amendments. SRP requests clarity on how the Board of Directors weighs RAPC endorsements and stakeholder comments in their decision-making process. This information may be helpful for transparency and ensuring all stakeholders are appropriately considered in final decisions and will help in understanding how appeals to the Board of Directors will be handled.

In addition, the BPM does not mention an appeal process for RAPC members who do not endorse amendments. SRP recommends the WPP consider outlining a clear process for such appeals to the Board of Directors. An appeal process may help ensure all participants have a fair opportunity to be heard at all levels of the decision-making process.

General Comment

SRP is encouraged by the WPP’s ongoing efforts in the development of WRAP BPMs and will continue to provide comments on relevant sections within this BPM.