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

No response submitted.

02: Please supply any comments related to the Derivation of the CCH Analysis Components section (3).

No response submitted.

03: Please supply any comments related to the Derivation of the CCH Analysis Components - Load (Demand) section (3.1).

No response submitted.

04: Please supply any comments related to the Derivation of the CCH Analysis Components - Wind Resource Output section (3.2).

No response submitted.

05: Please supply any comments related to the Derivation of the CCH Analysis Components - Solar Resource Output section (3.3).

Powerex notes that the first sentence is this section incorrectly references wind data, as opposed to solar.

06: Please supply any comments related to the Derivation of the CCH Analysis Components - Run of River Output section (3.4).

Powerex notes that the first sentence is this section incorrectly references wind data, as opposed to run of river.

07: Please supply any comments related to the Derivation of the CCH Analysis Components - Interchange section (3.5).

Regarding Section 3.5.3 Further Modifications to Interchange, Powerex notes that the $6 carbon adjustment used to modify the California market price represents a rough average of actual carbon costs, and that the carbon costs will continue to change over time. Powerex suggests that the BPM be modified such that the carbon adjustment applied to each year should be the actual California Carbon Allowance cost for the applicable vintage year ($ per MTCO2e), multiplied by the prevailing California Air Resources Board unspecified emissions rate for that year (presently 0.428 MTCO2e/MWh).

08: Please supply any comments related to the Determining the CCHs section (4).

No response submitted.

General Comment