01: Please supply any comments related to the Introduction, Definitions, or Background sections.
None
02: Please supply any comments related to the Election of Transition Binding Seasons – Election Process section (3.1).
None
03: Please supply any comments related to the Election of Transition Binding Seasons – Deferral of a Participant’s Binding Season section (3.2).
None
04: Please supply any comments related to the Election of Transition Binding Seasons – Transition Binding Seasons and Non-Binding Seasons section (3.3).
None
05: Please supply any comments related to the Transition Binding Season Participation section (4).
None
06: Please supply any comments related to the Transition Binding Season Participation – Non-Binding Season Participation section (4.1).
None
07: Please supply any comments related to the Transition Binding Season Participation – Option to Defer First Binding Season for All Participants section (4.2).
None
08: Please supply any comments related to the Excused Transition Deficits section (5).
None
09: Please supply any comments related to the Excused Transition Deficits – How to Obtain an ETD section (5.1).
None
10: Please supply any comments related to the Excused Transition Deficits – Limits on Megawatts to which ETDs can be Applied section (5.2).
City Light recommends that the “Percentage Value to be Multiplied by Participant FSPRM” range is 100%, 75%, and 50% for their respective Summer/Winter season pairs. City Light agrees that participants should be encouraged to address gaps in their portfolio and recognizes the challenges of uncertainty related to the next BPA Power contract, next day market development, and resource development delays. It is likely that the next BPA Power Contract will not be executed until the Summer 2025 season has started.
11: Please supply any comments related to the Excused Transition Deficits – Reduced Deficiency Charge once ETD is Applied section (5.3).
City Light recommends that the “Percentage Value Reduction for Portion of Monthly Capacity Deficiency to which ETDs Have Been Applied” range is 100%, 75%, and 50% for their respective Summer/Winter season pairs. City Light agrees that participants should be encouraged to address gaps in their portfolio and recognizes the challenges of uncertainty related to the next BPA Power contract, next day market development, and resource development delays.
12: Please supply any comments related to the Reduction of Monthly Capacity Deficiency Applicable to Legacy Agreements section (6).
For the No-JCAF Option, City Light suggests that there not be a reduction on a MW for MW bases in the maximum permitted use of ETDs for the same Transition Binding Season.
13: Please supply any comments related to the Adjustment of Revenue Allocations section (7).
City Light suggests that Participants who use the No-JCAF option should be included in the group of participants that ETD revenue is distributed. City Light recommends that the following language be deleted from Section 7: “and did not exercise the No-JCAF Option.”
14: Please supply any comments related to Appendix A – Senior Official Attestation – ETD
None
15: Please supply any comments related to Appendix B – Senior Official Attestation – No-JCAF Option
City Light recommends changing the Senior Official Attestation wording to reflect that the No-JCAF option does not result in the participant being capacity deficient for the transmission period. City Light suggests the following wording:
I, the undersigned, who, as [title], serves as a senior official of [Participant], hereby attest, in support of [Participant]’s request for a No-JCAF Option for __ forward showing listed resource(s), totaling ___ MW. Such deficiency is due to [Participant]’s inability to obtain assent from the supplier under a Legacy Agreement to the accreditation. [Participant] made commercially reasonable efforts to execute the accreditation form with the supplier under the Legacy Agreement, but the supplier was unable or unwilling to counter sign the accreditation form; and the foregoing statements are true, correct, and complete to the best of my knowledge and belief following due inquiry appropriate to the reliability and resource adequacy matters addressed herein.
General Comment
City Light recommends that policy choices that penalize entities for choosing a later binding seasons is counterproductive and should be reconsidered.