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

No comment at this time.

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

No comment at this time.

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

Do we need to provide language here that describes applicable portions of jointly owned units?

The following language is used in several places and is confusing, Section 3.1 IV “(network integration transmission service [NITS] from resources not designated as network resources or conditional firm long-term firm point-to-point [PTP])” and the confusion is around why it says “from resources not designated as network resources”.  Is this trying to protect against making capacity sales from already designated network resources?  If so, that seems like a problem for the seller and not an issue for WRAP to worry about. We would propose striking, and just leave it as NERC priority 6 (NITS and PTP), because a designated resource can utilize NERC priority 6 NITS.

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

In Section 3.2.1 we think “A System Sale for which a Participant is the buyer and a Participant is the seller” is better written as “A System Sale where buyer and seller are participants will...”

Similarly in Section 3.2.2. Participant Buyer – Non-Participant Seller, “A System Sale for which a Participant is a buyer, but a Participant is not the seller”, can be better written as  “…but a non-participant is the seller.”

Then in 3.2.3, “A System Sale for which a Participant is not the buyer” is better said as “A System Sale where a non-Participant is the buyer, and a Participant is the seller,”

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

The label for Table 1 is at the top where the label for Table 2 is at the bottom, we’d recommend moving the label for Table 2 to the top for consistency.

In table 1 under the less than 100% off take it requires re-submission for each Forward Showing, which seems unnecessary. If this is a long-term PPA for a portion of a resource that portion of the resource will not change from one Forward Showing to the next, can we utilize the JCAF once to reflect the full term of the contract, then attest each Forward Showing Year that it hasn’t changed?

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

In this section it says Firm capacity sales made by a Participant to parties outside the WRAP must be on the FS Submittal, does this preclude an entity from selling capacity products after the FS Submittal is complete because they would not be able to comply with including it in the FS Submittal if not transacted beforehand? It also says a JCAF is not required for sales to non-WRAP participants, but Table 1 contradicts that and says it is required the first time.

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

What is the practical difference between a sale and a transfer? Why do we need a separate type if they are both for the FS? There is also a disconnect here where the contract is submitted to the PO, but for other types of transactions we want to utilize the JCAF to avoid contract submissions. Why not either not require contract submission, since both Participants are submitting it in their FS, or utilize the JCAF/Attestations here as well?

There is a reference here to a seller using NITS which as explained above in prompt # 6 should be modified.

08: Please supply any comments related to Appendix A.

Typo “transtition” should be “transmission” in two places. APS also believes that we can remove the reference to NITS in this section, NITS is not transmission that can be used for off-system sales. Since this is the attestation for the seller there should only be point to point transmission used to the Contracted Capacity Firm Delivery Point.

09: Please supply any comments related to Appendix B.

No comment at this time.

10: Please supply any comments related to Appendix C.

No comment at this time.

11: Please supply any comments related to Appendix D.

No comment at this time.

General Comment

We believe that BPM 106 should also cover information related the risk of over/under performance assumed by purchaser and contingency reserve obligation assumed by purchaser that was added to the FS workbook and JCAF.