Timing doesn’t seem correct - How could a new participant in March of 2027 elect a Winter 27/28 Binding season. The participant has not been through an Advance Assessment so they do not have QCC's established for resources. With a limitation of 10% of resources getting a fleet average as a new resources they could not meet Forward Showing requirements, A new participant needs to have gone through an Advanced Assessment process in order to have QCC's and data usable for a Forward Showing submittal.
No response submitted.
In this sentence, “Each entity that becomes a Participant after the effective date of this BPM shall, at the time it executes a WRAPA, or at the time such Participant’s non-conforming WRAPA is filed with the Federal Energy Regulatory Commission, shall give notice of its elected first Transition Binding Season.”, would it be more accurate to say “…after the effective date of this BPM and prior to March 31, 2027” so that it captures the concept explained in the last paragraph of 3.1?
On the March 31, 2027 date, we believe this was selected because it is the forward showing deadline for the Winter 2027-2028 season. Although we think there is an early deadline than this to be included in the last transition period season, since they would also need to be included in the Advance Assessment of that season. We believe that makes the date October 31, 2025 which would be two years prior to the last transition period season start date. If this is accurate then I would replace March 31, 2027 in the recommendation above with October 31, 2025 as well.
No response submitted.