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

No comments submitted

02: Please supply any comments related to the Reduction in Sharing Calculation section.

Section 3 of BPM 210 does not provide guidance on how revenue from FS Deficiency Charges in a particular Binding Season is distributed to participants who did not have a Monthly Capacity Deficiency in the Forward Showing Program for that season.

03: Please supply any comments related to the Priorities of Access During the Transition Period When Aggregate Holdback Requirements Are Limited section.

No comments submitted

05: Please supply any comments related to the Access to Voluntarily Offered Capacity section.

Section 4 of BPM 210 does not specify how a participant who had Monthly Capacity Deficiency yet did not pay Forward Showing Deficiency charges as result of using the ETD or No-JCAF option would be placed into a priority tier. As a comparison BPM 109 provides specific guidance for this scenario so it would helpful to do the same in BPM 210.

General Comment

10/6 PSE comments