01 Please supply any comments related to the Introduction, Definitions, or Background sections.
No response submitted.
02 Please supply any comments related to the Applicable Index Prices section.
No response submitted.
03 Please supply any comments related to the Settlement Pricing Overview and Components introduction section.
No response submitted.
04 Please supply any comments related to the Settlement Pricing Overview and Components - Total Settlement Price section.
No response submitted.
05 Please supply any comments related to the Settlement Pricing Overview and Components - Holdback Settlement Price section.
No response submitted.
06 Please supply any comments related to the Settlement Pricing Overview and Components – Energy Declined Settlement Price section.
Avista would prefer the following:
“The Energy Declined Settlement Price is the lesser greater of (i) 0.08 times the Total Settlement Price, or (ii) the Real-Time Applicable Index Price for the hour.” This approach acknowledges the seller's opportunity to transact in either DA or the RT market vs providing holdback.
07 Please supply any comments related to the Settlement Pricing Overview and Components - Application of Pricing and Quantities for Holdback Requirements and Energy Deployment Transactions section.
No response submitted.
08 Please supply any comments related to the Settlement Pricing Overview and Components - Make Whole Adjustment section.
Avista believes the Make Whole Adjustment should include a mechanism compensating the seller for all incremental Washington CCA obligation incurred during energy deployments.
09 Please supply any comments related to the Settlement Pricing Overview and Components - Allocation of Holdback Settlement to Multiple Participants section.
No response submitted.
10 Please supply any comments related to the Settlement Pricing Overview and Components - Transmission Service section.
No response submitted.
11 Please supply any comments related to the Settlement Pricing Overview and Components - Settlement Pricing for Subregions section.
No response submitted.
General Comment