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

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02: Please supply any comments related to the Calculating the Deficiency Charge section (3).

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03: Please supply any comments related to the Calculating the Deficiency Charge - Calculating the Deficiency section (3.1).

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04: Please supply any comments related to the Calculating the Deficiency Charge - Calculating the Deficiency Charge section (3.2).

Section 3.2 Calculating Deficiency Charge

BOX Formula 3 refers to a Winter Season Annual CONE factor in accordance with Section 3.4 which does not seem to exist.

The layering of costs could grow to a point of seeming excessive, depending on the value of the CONE that is used. It would be helpful to have examples which demonstrate the magnitude of the potential penalty a Participant might have assigned for one or two consecutive deficiency seasons.

Although the tariff is explicit that the CONE be a based on a new natural gas generator, there is still a significant range of costs that could be included, or that could vary widely. Depending on cost assumptions adopted, the penalty could significantly change and Participants should understand the range of a potential penalty.

05: Please supply any comments related to the Calculating the Deficiency Charge - Determining Certain Components of the Deficiency Charge Calculation section (3.3).

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06: Please supply any comments related to the Timing of Deficiency Charge Revenue Collection section (4).

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07: Please supply any comments to the Allocation of Revenues from Deficiency Charges section (5).

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08: Please supply any comments related to the Board Appeal Process section (6).

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General Comment