Comment Text:
After much thought we would suggest increasing storage costs to allow for more
convergence. A hybrid approach with a yearly observation period would decrease complexity and be beneficial for all. The current review process which takes at least 3 years to affect change seems too long and would produce negative outcomes for producers. I suggest using current VSR measures of 80% of full carry to provide a monthly deliverable storage increase of 5c, and 50% of full carry to provide a monthly deliverable storage decrease of 5c.
