12: Please supply any comments related to the Reduction of Monthly Capacity Deficiency Applicable to Legacy Agreements section (6).




Sept. 14, 2023, 12:33 p.m.
ANNE SIMON | Public

Tariff defines this "Legacy Agreement: A power supply agreement entered into prior to October 1, 2021."

BPM should include the date since it is already in the Tariff


Sept. 18, 2023, 9:05 a.m.
MICHAEL WATKINS | Seattle C…

For the No-JCAF Option, City Light suggests that there not be a reduction on a MW for MW bases in the maximum permitted use of ETDs for the same Transition Binding Season.


Sept. 18, 2023, 10:59 a.m.
JONATHAN HART | EWEB

The no-JCAF option may be detrimental to a party that has the majority of their capacity served from a single source (say the BPA contract). For example, if an LRE had 400 of capacity and was unable to attain a JCAF, then the LRE would only be able to claim 100 MWs of No-JCAF exception, and would otherwise be exposed to transition costs for the remaining 300 MWs. On top of that, the interplay between no-JCAF and transition excepting limit would dramatically increase risk of unmitigated exposure capacity shortfall during the transition.  Is there an alternate treatment for No JCAF that could be considered?


Sept. 18, 2023, 2:49 p.m.
TYLER MOORE | Arizona P…

No comments at this time 


Sept. 18, 2023, 4:29 p.m.
SANDEAP REDDY | Puget Sou…

No comment at this time.


Sept. 18, 2023, 9:34 p.m.
BENJAMIN FAULKINBERRY | PacifiCor…
No response submitted.