Under the proposed approach, the Annual Deficiency Charge is associated with the Binding Season in which the max monthly deficiency occurs. If the max monthly deficiency is equal in both Summer and Winter, the Charge is split 50% / 50%.

SRP recommends that when a Participant has deficiencies in both Summer and Winter, the Annual Deficiency Charge be allocated between the Summer and Winter Binding Seasons on a pro rata basis using the highest monthly deficiency in each Binding Season. This could potentially better reflect deficiencies that occur in both Summer and Winter Binding Seasons rather than assigning the full annual charge to the season with the higher max deficiency.