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APS wonders if this Attestation could be made available for all resources that don’t have GADS data available, rather than limited to Thermal Resources that are not required to report GADS data. It seems odd that a Participant can only submit equivalent data when GADS is not required, rather than being able to submit and attest to the data in place of GADS data. If this section needs to continue as being only for resources that aren’t required to report GADS data, the criteria or link to the criteria for GADS requirements would be helpful.
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