01: Please supply any comments related to the Introduction, Definitions, or Background sections.
The Introduction states that the 3 year Transition Period goes from Summer '25 - Winter '27-'28 however our understanding was that the 1st Binding Season is scheduled for Summer '26. Would be helpful to get confirmation on this.
02: Please supply any comments related to the Election of Transition Binding Seasons – Election Process section (3.1).
No comment at this time.
03: Please supply any comments related to the Election of Transition Binding Seasons – Deferral of a Participant’s Binding Season section (3.2).
Sec 3.2 states that Participants may elect to defer their Transition Binding Season to a later date within the Transition Period. PSE would like to know if it were possible to change their initial choice of Transition Binding Season to an earlier date within the Transition Period.
04: Please supply any comments related to the Election of Transition Binding Seasons – Transition Binding Seasons and Non-Binding Seasons section (3.3).
No comment at this time.
05: Please supply any comments related to the Transition Binding Season Participation section (4).
No comment at this time.
06: Please supply any comments related to the Transition Binding Season Participation – Non-Binding Season Participation section (4.1).
No comment at this time.
07: Please supply any comments related to the Transition Binding Season Participation – Option to Defer First Binding Season for All Participants section (4.2).
No comment at this time.
08: Please supply any comments related to the Excused Transition Deficits section (5).
No comment at this time.
09: Please supply any comments related to the Excused Transition Deficits – How to Obtain an ETD section (5.1).
Sec. 5.1 explains how to submit an Excused Transition Deficit (ETD) however it does not include a deadline by which a participant must submit an attestation receive one for a given Excused Transition Deficit. Would be great to get additional clarity on that.
10: Please supply any comments related to the Excused Transition Deficits – Limits on Megawatts to which ETDs can be Applied section (5.2).
Sec. 5.2 shows a table for the percentages used to calculate the ETD capacity for a given Transition Binding Season in the Transition Period, which shows Summer '25 as the first Binding Period. If the 1st Binding Season in Transition Period is actually Summer '26 , PSE would like to know how the table shown in the BPM would change.
11: Please supply any comments related to the Excused Transition Deficits – Reduced Deficiency Charge once ETD is Applied section (5.3).
Similar to the previous section, Sec. 5.3 shows a table for the percent discount used to calculate the deficiency charges which shows Summer '25 as the first possible Binding Period. If the 1st possible Binding Season in the Transition Period is actually Summer '26, PSE would like to know how the table shown in the BPM would change.
Also, along with the example provided in the BPM, it would be helpful to see the full calculation of the Total Deficiency Charges as shown below -
Total Deficiency Charges =
(Total Deficiency MW - ETD MW ) * Deficiency Charge ($/MW)
+ (ETD MW) * Deficiency Charge ($/MW) * (1 - Reduction %)
12: Please supply any comments related to the Reduction of Monthly Capacity Deficiency Applicable to Legacy Agreements section (6).
No comment at this time.
13: Please supply any comments related to the Adjustment of Revenue Allocations section (7).
No comment at this time.
14: Please supply any comments related to Appendix A – Senior Official Attestation – ETD
No comment at this time.
15: Please supply any comments related to Appendix B – Senior Official Attestation – No-JCAF Option
No comment at this time.
General Comment
No further comment at this time.