I. Market Design
A. Delete the clause beginning "at a minimum ...." from the title.

Paragraph 7 beginning "If the Commission insists . . . ."

add "As discussed by Mr. Comnes,"  at the beginning of the sentence 
delete the "at minimum, $250 per MWh - and"
delete the rest of the paragraph (except footnote 4) beginning with "This is 
so for several reasons . . . "  I would put footnote 4 in as text.