City Light has no comments on this section of the BP.
Shell Energy opposes the requirement that aggregated qualified resources less than 1 MW be located within 10 miles of each other. It appears this will disqualify many behind the meter resources unnecessarily from providing benefits to the participating resource owner/contract holder and the wider program footprint.
Agree with Shell. Delete language after first sentence. Connectivity to common trnamission injection point should be sufficient.
- 2nd paragraph - '...in close proximity...' - This feel pretty arbitrary. For one the PO could decide 50 miles is close enough for another it needs to be within 25? Guidelines would be good.
July 14, 2023, 12:41 p.m.
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Please identify the means by which the following should be communicated “For Qualifying Resources that are requested to be aggregated, the following information should be provided to the PO.” Can this be done within the Advance Assessment data request workbook?
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Need to include instructions on how to handle aggregation of <1 MW resources that are not located with either a 10 mile radius or two electrical buses, whichever is shorter.
No comment on this section.
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