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"Participants shall document all loads in their FS Demonstration, including excluded load"
Including 'excluded load' - how/were do you excluded load?
"Subregion with the lower monthly FSPRM to the load in the Subregion with the higher monthly FSPRM"
Why is the single workbook requirement, to provide transmission from lower FSPRM to Higher PRM. A participant may not care about the lower FS PRM but wants a single system and be willing to use the higher PRM because that is the subregion were resource are located.
This rule of using a single workbook should be expanded to ALL conditions
"In accordance with this, a Participant may be required to submit separate FS demonstrations, even as to loads residing in the same Subregion"
Hard to forward contract with this uncertainty combined with uncertainty associated with CCH and PRM which change each season and each year and which are also subject to sole discretion of PA. Seems like we need some sort of pre-FS consultation process to avoid surprises/fines.
If This determination is made after FS Submittal, it should be for future seasons, and not a deficiency in the current submittal process