Submissions
p. p. 0
Submissions In conclusion, the SBA respectfully submits that the Board should consider risk allocation of the proposed AARs in the presence of volatile marginal costs, ensure administrative costs are welljustified, and acknowledge the need...
AI summary The SBA submits that the Board should consider risk allocation of proposed AARs in light of volatile marginal costs, ensure administrative costs are well-justified, and provide clarity on deferred RtR costs to ensure fairness across customer classes.