01: Please supply any comments related to the Introduction, Definitions, or Background sections.

In the definition for Cumulative Delivery Failure Window it states that it is a rolling wind of five Forward Showing Years. Is this correct, because APS recalls a Forward Showing Year being one year and that the Cumulative Delivery Failure Window also was one Forward Showing Year.

02: Please supply any comments related to the Notification of Anticipated Delivery Failure section (3) .

In section 3, item 4 it instructs Participants that are expecting to fail on deliver of Holdback to adjust the tag. Since this section is written in a way that a Participant is anticipating not being able to deliver, would it be best to not adjust the tag until there has been confirmation that deliver failure will occur? Alternatively, we could change the perspective of the section from anticipation of non-delivery to actual non-delivery rather than anticipation of non-delivery.

03: Please supply any comments related to the Calculation of Delivery Failure Charge section (4).

APS requests additional clarity be added to the section around what is done when there is a negative Day-Ahead Price and Real-Time Price when energy delivery failure occurs. We believe the current language says that the highest index price over the last 30 days will be used to calculate the delivery failure. It seems misaligned to charge this amount, if the actual price during failure was negative in both day ahead and real-time markets. This indicates market surplus is available in both day ahead and real-time, and for that reason a $0 penalty may be more appropriate.

04: Please supply any comments related to the Dollar Limit on Delivery Failure Charges During a Forward Showing Year section (5).

No comments at this time.

05: Please supply any comments related to the Allocation of Revenues from Payment of Delivery Failure Charges section (6).

No comments at this time.

06: Please supply any comments related to the Waiver of an Energy Deployment Obligation section (7).

No comments at this time.

07: Please supply any comments related to the Possible Expulsion for Repeated Energy Delivery Failures section (8).

No comments at this time.

General Comment