02 Please supply any comments related to the Applicable Index Prices section.




July 27, 2023, 2:09 p.m.
LORI HERMANSON | Avista
No response submitted.

Aug. 4, 2023, 1:12 p.m.
LINDSEY SCHLEKEWAY | NVE
No response submitted.

July 31, 2023, 2:37 p.m.
KATIE NELSON | BPA
  • Applicable Index Prices: The important issue here is assuring a process/mechanism to allow for future changes to this BPM’s chosen Index Prices.  Even more so to sync with the future market landscape (CAISO/SPP M+/Other)
  • NW Subregion: This will likely need to change prior to the first binding season.

Aug. 1, 2023, 2:27 p.m.
RAJ HUNDAL | PWX
No response submitted.

Aug. 2, 2023, 2:07 p.m.
JOHN MAYHEW | Public Se…
No response submitted.

Aug. 3, 2023, 7:43 a.m.
BENJAMIN FAULKINBERRY | PacifiCor…

PAC would appreciate more flexible language in this section which considers possible changes in nature and number of program subregions due to program membership change as well as DA market implementations.


Aug. 3, 2023, 12:09 p.m.
SANDEAP REDDY | Puget Sou…

No comment.


Aug. 4, 2023, 7:26 a.m.
LEAH MARQUEZ-GLYNN | Tacoma Po…
No response submitted.

Aug. 4, 2023, 1:14 p.m.
MARA KONTOS | Seattle C…

Regarding the Northwest Subregion: 

“The Day-Ahead Applicable Index Price is the ICE Day-Ahead (DA) Mid-Columbia (Mid-C) Index.” 

Where will this be posted for verification? What happens when there are discrepancies? 

“The Real-Time Applicable Index Price is the Powerdex real-time Mid-Columbia Index.” 

What happens when the RT Index price is not available? Historically, Powerdex can be 10-15 days late. 


Aug. 4, 2023, 2:02 p.m.
IAN WHITE | SE

Shell Energy generally supports using the applicable on peak / off-peak indices for Mid-Columbia (Mid-C) and Palo Verde; however, due to Washington Cap and Invest, there may be variability and inconsistency in how real-time prices are being reported for the Powerdex real-time Mid-C index.  Powerdex may no longer be the appropriate real-time index to use for the Northwest Subregion.

In addition, language should be added which speaks to two items, the first being other formal indices which may be formed, e.g., Mid-C Non-Washington Sink.  Secondly, successor pricing mechanisms applicable under organized market constructs.


Aug. 4, 2023, 3:25 p.m.
CAMILLE CHRISTEN | Idaho Pow…
No response submitted.

Aug. 4, 2023, 3:35 p.m.
TYLER MOORE | Arizona P…

A slight correction to move “(FMM)” to after the words “fifteen minute market) since “market” is the 2nd M in FMM.