Submitted Responses
2026-NTFP-08 (Deficiency Charge Calculation)
Please supply any comments related to the proposed changes in BPM 107 - Forward Showing Deficiency Charge
Please supply any comments related to the proposed changes in the WRAP Tariff
Similarly, the Annual Deficiency Charge is based on the max monthly deficiency for the Forward Showing Year and is associated with the Binding Season in which that max occurs.
SRP recommends revising the calculation so that when a Participant has deficiencies in both Binding Seasons, the Annual Deficiency Charge is allocated between Summer and Winter on a pro rata basis using the highest Monthly Deficiency with each season.
General Comment
SRP generally supports the proposed approach of separating Monthly and Annual Deficiency Charge calculation. However, SRP recommends using a pro rata approach for the annual charge when a Participants has deficiencies in both Summer and Winter.
Under the proposed approach, the Annual Deficiency Charge is associated with the Binding Season in which the max monthly deficiency occurs. If the max monthly deficiency is equal in both Summer and Winter, the Charge is split 50% / 50%.
SRP recommends that when a Participant has deficiencies in both Summer and Winter, the Annual Deficiency Charge be allocated between the Summer and Winter Binding Seasons on a pro rata basis using the highest monthly deficiency in each Binding Season. This could potentially better reflect deficiencies that occur in both Summer and Winter Binding Seasons rather than assigning the full annual charge to the season with the higher max deficiency.