No response submitted.
City Light suggests QCCs for Run of the River Hydro resources should have the option of being calculated by the Participant owners and the results are provided to the PO for review, or by historical performance of the resource.
No response submitted.
Powerex suggests that for new Run of River (RoR) Resources with less than three years of historical generation data, simulated generation data based on historical inflows could be provided in the Advanced Assessment and used to determine the QCC. When at least three years of generation data is available, the QCC could be determined without the use of simulated data, instead using the historical generation output in Capacity Critical Hours starting when the Resource reached COD.
No response submitted.
No response submitted.
No response submitted.
No response submitted.
No response submitted.
Are the “Customer Resources” and “Public Utility Regulatory Policies Act (PURPA) Qualifying Facility Resources” sections on p. 29 intended to be part of the Hydro Resources section, as they appear to be? They seem broader than just Hydro and it seems like they should be their own subsections.
In that regard, the “Public Utility Regulatory Policies Act (PURPA) Qualifying Facility Resources” header seems inaccurate based on the text of that section. The text itself indicates that it applies to resources including but not limited to PURPA qualifying facilities so limiting the header to PURPA is misleading.
The option available under that section to non-dispatchable contracted-for resources, or resources that require the purchase to take energy as available from the resource, should be available to such resources regardless of resource type and regardless of whether the contract is with a PURPA qualifying resource or not.
No response submitted.
The BPM should clearly define what assumptions go into the Baseline upper limit QCC calculation and also clearly define what, if any, assumptions are allowed for alternative lowered QCC values.
The BPM should state what, if any, maintenance outage assumptions are to be used for Advance assessment compared to the maintenance outages used for the FS program. Should the advanced assessment (given the two plus years planning timeline) use outage assumptions based on historical actual unforced outages instead of “planned outages” for the forthcoming FS season?
Please specify exactly what result data is provided to the program operator (PO). Is it simply a screenshot of the QCC values or is it all the input data, assumptions and model workbooks?
For MidC projects, Buyer has to review assumptions, validate results, get JCAFs signed and model QCC in the FS workbook. Please establish clear deadlines for the Seller (MidC operators) to provide draft QCC results and final QCC results prior to the FS deadlines consistent with the dissemination of QCC data by the PO for all the other non-hydro resources. This BPM should also clearly state what elements of the model workbook and assumptions have to be provided by the Seller to the Buyer for validation purposes, JCAF signing and FS modeling. For example, the BPM should clearly state that the Seller should provide both the baseline QCC (maximum allowed by the program) as well as the QCC that the Seller may be modeling for their own internal risk management purposes.
Per the tariff, 'If ten years of historic data is not available for the Storage Hydro Qualifying Resource, the Participant may alternatively employ data on the same metrics from a demonstrably comparable facility or apply another method that provides reasonable confidence in the reliability of the predicted values, as more fully set forth in the Business Practice Manuals.' We did not see these metrics clearly set forth in this BPM.