01: Please supply any comments related to the Introduction, Definitions, or Background sections.
No comments at this time
02: Please supply any comments related to the Election of Transition Binding Seasons – Election Process section (3.1).
In this sentence, “Each entity that becomes a Participant after the effective date of this BPM shall, at the time it executes a WRAPA, or at the time such Participant’s non-conforming WRAPA is filed with the Federal Energy Regulatory Commission, shall give notice of its elected first Transition Binding Season.”, would it be more accurate to say “…after the effective date of this BPM and prior to March 31, 2027” so that it captures the concept explained in the last paragraph of 3.1?
On the March 31, 2027 date, we believe this was selected because it is the forward showing deadline for the Winter 2027-2028 season. Although we think there is an early deadline than this to be included in the last transition period season, since they would also need to be included in the Advance Assessment of that season. We believe that makes the date October 31, 2025 which would be two years prior to the last transition period season start date. If this is accurate then I would replace March 31, 2027 in the recommendation above with October 31, 2025 as well.
03: Please supply any comments related to the Election of Transition Binding Seasons – Deferral of a Participant’s Binding Season section (3.2).
No comments at this time
04: Please supply any comments related to the Election of Transition Binding Seasons – Transition Binding Seasons and Non-Binding Seasons section (3.3).
No comments at this time
05: Please supply any comments related to the Transition Binding Season Participation section (4).
No comments at this time
06: Please supply any comments related to the Transition Binding Season Participation – Non-Binding Season Participation section (4.1).
The paragraph mentions a non-binding participant would not be subject to mandatory holdback etc, but at the end of the paragraph it contradicts that by saying they will be subject to “….Operations Program requirements.” We believe this should say “other Operations Program requirements” similarly to how it reads “…subject to all other FS program (requirements)”.
07: Please supply any comments related to the Transition Binding Season Participation – Option to Defer First Binding Season for All Participants section (4.2).
If this section only applies to delaying Summer 2025, does it still need to be included since the timeframe/decision on that delay has passed? If there is potential for a future vote to delay past Summer 2026 that is allowed then this section can remain. But, according to section 15.4.1 of the Tariff “The deferral vote may only occur for the first Binding Season of the WRAP.”, which we believe to be Summer 2025. Potentially, after a delay is decided the new season becomes the first Binding Season and the Tariff language and BPM is unclear to that effect.
08: Please supply any comments related to the Excused Transition Deficits section (5).
No comments at this time
09: Please supply any comments related to the Excused Transition Deficits – How to Obtain an ETD section (5.1).
No comments at this time
10: Please supply any comments related to the Excused Transition Deficits – Limits on Megawatts to which ETDs can be Applied section (5.2).
No comments at this time
11: Please supply any comments related to the Excused Transition Deficits – Reduced Deficiency Charge once ETD is Applied section (5.3).
We believe that the full charges associated with section 17.2 of the Tariff would be considered after the ETD is applied in terms of the max Summer and Winter deficiency variable of the calculation in this section. If accurate the addition of that clarification would be supported by APS.
12: Please supply any comments related to the Reduction of Monthly Capacity Deficiency Applicable to Legacy Agreements section (6).
No comments at this time
13: Please supply any comments related to the Adjustment of Revenue Allocations section (7).
Is it accurate to say that a Participant could pay no Deficiency Charge by utilizing ETDs under the Section 17.3 of the Tariff, our reading says that they would pay a reduced Deficiency Charge. If accurate, then the wording in this section should be updated to reflect the paying of reduced Deficiency Charge does not result in a Participant with no Deficiency Charges”.
14: Please supply any comments related to Appendix A – Senior Official Attestation – ETD
No comments at this time
15: Please supply any comments related to Appendix B – Senior Official Attestation – No-JCAF Option
No comments at this time
General Comment
No comments at this time