COMMENT FOR BPM 106 - Qualifying Contracts

Submitted April 11, 2024, 3:45 p.m.



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

SRP request clarification on how the ‘Contracted Capacity Firm Delivery Point’, as defined, interacts with or is impacted by the implementation of a MOD-30 system.

02: Please supply any comments related to the Contracts Eligible for QCC value section (3).

No response submitted.

03: Please supply any comments related to the Contracts Eligible for QCC value - Resource-Specific Capacity Agreements section (3.1).

No response submitted.

04: Please supply any comments related to the Contracts Eligible for QCC value - System Sale section (3.2).

No response submitted.

05: Please supply any comments related to the Joint Contract Accreditation Forms section (4).

SRP recommends the WPP include a sample completed JCAF or a detailed walkthrough of the form filling process. This has the potential to assist participants in accurately completing and submitting these forms.

Further, SRP encourages the WPP to provide explicit guidance in regards to the actions a participant should take and the implications of being unable to obtain a signature on the JCAF. This may provide clarity to participants on the process and potential consequences.

06: Please supply any comments related to the Calculating Net Contract QCC section (5).

SRP appreciates the detail provided on the methodology for Calculating Net Contract QCC. To further assist participants, SRP recommends the WPP provide a detailed example calculation, showcasing the step-by-step process and how various contract types are handled within this framework.

To confirm the submission and handling of sensitive information required for QCC calculations, SRP recommends the BPM reference section 10 (Treatment of Confidential and Commercially Sensitive Information of Participants) of the Tariff.

07: Please supply any comments related to the Resource Adequacy Transfers (RA Transfers) section (6).

SRP recommends the WPP include a necessary detail as it relates to any notification and approval process for RA Transfers to enhance clarity and ensure consistency in the application process for all WRAP participants.

08: Please supply any comments related to Appendix A.

No response submitted.

09: Please supply any comments related to Appendix B.

No response submitted.

10: Please supply any comments related to Appendix C.

No response submitted.

11: Please supply any comments related to Appendix D.

No response submitted.

General Comment

SRP is encouraged by the WPP’s ongoing efforts in the developing of WRAP BPMs and has provided comments on relevant sections within this BPM.