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).
Timing doesn’t seem correct - How could a new participant in March of 2027 elect a Winter 27/28 Binding season. The participant has not been through an Advance Assessment so they do not have QCC's established for resources. With a limitation of 10% of resources getting a fleet average as a new resources they could not meet Forward Showing requirements, A new participant needs to have gone through an Advanced Assessment process in order to have QCC's and data usable for a Forward Showing submittal.
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).
Should include that Non-Binding Participant can participate in Operations Program through voluntary participation/holdback, and may have deficiency's served based on the tiered participation levels.
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 response submitted.
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).
No response submitted.
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).
Do Transition Period Capacity Deficiency Charges utilize the '...Cone Factor' (Tariff 17.2.7 and 17.2.8), If the expectation of the Transition Period is to get participants to participate in the program even as they have known deficits and are incentivized to do that through lower Deficiency Charges, this seems like it penalizes the same participants for becoming binding. As more participants join that are deficit (paying reduced charge, the charge is increasing due to the total program deficit of ALL participants!
So, participant A becomes binding with a known deficit (expecting to pay reduced charges), party B and C do the same, now as a combined group they push the 'Aggregate Capacity Deficiency' into a higher level and increase the Cone Factor causing the reduced deficiency charge to increase!
Cone Factor should be set to 1 for the ALL participants in Transition Period so participants can actually evaluate this cost/charge with some expectation.
This issue continues to compound for an entity to become binding, pay increased charges, and watch those payments be distributed to other parties under the Revenue Allocation process. These all seem to be a deterrent to getting participants from becoming binding before they are absolutely sure they meet FS requirements without possibility of deficiencies.
12: Please supply any comments related to the Reduction of Monthly Capacity Deficiency Applicable to Legacy Agreements section (6).
Tariff defines this "Legacy Agreement: A power supply agreement entered into prior to October 1, 2021."
BPM should include the date since it is already in the Tariff
13: Please supply any comments related to the Adjustment of Revenue Allocations section (7).
Simply a deterrent for any participant to become binding before they can meet all FS requirements without question.
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
Please see attached comments from BPA.