No response submitted.
No response submitted.
Section 3.2.5.2
The section regarding contracts for which the Participant cannot obtain a JCAF is in the Transition Exceptions section. This implies that the No JCAF exception will only apply during the transition period. However, many Participants have legacy contracts that will be in place beyond the transition period. In these instances, the exception should be allowed to be permanent. For example, Participants have legacy PURPA contracts with terms of twenty or more years, in some cases with generators who may be unwilling to sign a JCAF. Further, the exception should apply to contracts executed after October 1, 2021 in cases where the Participant is unable to require the seller to execute a JCAF. Again, this can be the case with PURPA contracts, where the utility is required to purchase the output from the facility but has limited ability to impose additional requirements beyond the PPA.
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Seattle City Light has no comments on this section.
In section 3.2.5.1 it states, “To obtain an ETD for a Binding Season, the Participant must provide a Senior Official Attestation as part of their FS Submittal,…’ Is this necessary, what if a Participant is found deficit by the PO after FS submission? That entity then can't get an ETD on the deficiency since it didn't submit this attestation at FS Deadline. Should we amend to say they must submit this if applying for ETD as part of FS Demonstration, but they can also receive an ETD if they are found to be deficit after the FS Deadline and submit the needed information for an ETD.
No response submitted.
The formatting of this paragraph was a little goofed up.