01: Please supply any comments related to the Introduction, Definitions, or Background sections.
No response submitted.
02: Please supply any comments related to the Election of Transition Binding Seasons – Election Process section (3.1).
No response submitted.
03: Please supply any comments related to the Election of Transition Binding Seasons – Deferral of a Participant’s Binding Season section (3.2).
No response submitted.
04: Please supply any comments related to the Election of Transition Binding Seasons – Transition Binding Seasons and Non-Binding Seasons section (3.3).
No response submitted.
05: Please supply any comments related to the Transition Binding Season Participation section (4).
No response submitted.
06: Please supply any comments related to the Transition Binding Season Participation – Non-Binding Season Participation section (4.1).
No response submitted.
07: Please supply any comments related to the Transition Binding Season Participation – Option to Defer First Binding Season for All Participants section (4.2).
"except if the Participants vote to delay implementation only of the Operations Program portion of the first Binding Season and retain the binding FS Program portion of the first Binding Season” What happens to the compliance charges in this case? except if the Participants vote to delay implementation only of the Operations Program portion of the first Binding Season and retain the binding FS Program portion of the first Binding Season” What happens to the compliance charges in this case?
08: Please supply any comments related to the Excused Transition Deficits section (5).
No response submitted.
09: Please supply any comments related to the Excused Transition Deficits – How to Obtain an ETD section (5.1).
What constitues a commerically reasonable effort and who decides?
10: Please supply any comments related to the Excused Transition Deficits – Limits on Megawatts to which ETDs can be Applied section (5.2).
No response submitted.
11: Please supply any comments related to the Excused Transition Deficits – Reduced Deficiency Charge once ETD is Applied section (5.3).
No response submitted.
12: Please supply any comments related to the Reduction of Monthly Capacity Deficiency Applicable to Legacy Agreements section (6).
The no-JCAF option may be detrimental to a party that has the majority of their capacity served from a single source (say the BPA contract). For example, if an LRE had 400 of capacity and was unable to attain a JCAF, then the LRE would only be able to claim 100 MWs of No-JCAF exception, and would otherwise be exposed to transition costs for the remaining 300 MWs. On top of that, the interplay between no-JCAF and transition excepting limit would dramatically increase risk of unmitigated exposure capacity shortfall during the transition. Is there an alternate treatment for No JCAF that could be considered?
13: Please supply any comments related to the Adjustment of Revenue Allocations section (7).
Suggest changing “A Participant that, as a result of applying ETDs under Section 17.3 of the WRAP Tariff, pays no Deficiency Charge as to a Binding Season, shall not be deemed...” to ‘...pays zero Deficiency Charge...’
14: Please supply any comments related to Appendix A – Senior Official Attestation – ETD
No response submitted.
15: Please supply any comments related to Appendix B – Senior Official Attestation – No-JCAF Option
No response submitted.
General Comment