Do Transition Period Capacity Deficiency Charges utilize the '...Cone Factor' (Tariff 17.2.7 and 17.2.8),   If the expectation of the Transition Period is to get participants to participate in the program even as they have known deficits and are incentivized to do that through lower Deficiency Charges, this seems like it penalizes the same participants for becoming binding.  As more participants join that are deficit (paying reduced charge, the charge is increasing due to the total program deficit of ALL participants! 

So, participant A becomes binding with a known deficit (expecting to pay reduced charges), party B and C do the same, now as a combined group they push the 'Aggregate Capacity Deficiency' into a higher level and increase the Cone Factor causing the reduced deficiency charge to increase!

Cone Factor should be set to 1 for the ALL participants in Transition Period so participants can actually evaluate this cost/charge with some expectation.

This issue continues to compound for an entity to become binding, pay increased charges, and watch those payments be distributed to other parties under the Revenue Allocation process.  These all seem to be a deterrent to getting participants from becoming binding before they are absolutely sure they meet FS requirements without possibility of deficiencies.

City Light recommends that the “Percentage Value Reduction for Portion of Monthly Capacity Deficiency to which ETDs Have Been Applied” range is 100%, 75%, and 50% for their respective Summer/Winter season pairs.  City Light agrees that participants should be encouraged to address gaps in their portfolio and recognizes the challenges of uncertainty related to the next BPA Power contract, next day market development, and resource development delays.

We believe that the full charges associated with section 17.2 of the Tariff would be considered after the ETD is applied in terms of the max Summer and Winter deficiency variable of the calculation in this section. If accurate the addition of that clarification would be supported by APS.  

Similar to the previous section, Sec. 5.3 shows a table for the percent discount used to calculate the deficiency charges which shows Summer '25 as the first possible Binding Period. If the 1st possible Binding Season in the Transition Period is actually Summer '26, PSE would like to know how the table shown in the BPM would change. 

Also, along with the example provided in the BPM, it would be helpful to see the full calculation of the Total Deficiency Charges as shown below -

Total Deficiency Charges  =

(Total Deficiency MW - ETD MW ) * Deficiency Charge ($/MW)

+ (ETD MW) * Deficiency Charge ($/MW) * (1 - Reduction %)