This paper employs Castilian Spanish data to examine the issue of rising pitch accents and their phonological analysis. The preliminary Sp_ToBI annotation conventions are shown to be inadequate for representing the Castilian Spanish data, and therefore a revision is proposed. Through an examination of data on Castilian Spanish rising accents in a variety of sentence types, two primary contributions are made in this paper. First, new empirical data on the inventory of rising pitch accents in Castilian Spanish is provided, showing that there is a three-way contrast that must be accounted for. Secondly, an analysis of rising accents is proposed that is based on the secondary association of pitch accent tones that not only is able to account for the three-way contrast in rising accents, but which offers a more straightforward manner of assigning starredness in bitonal pitch accents.