01 Please supply any comments related to the Introduction, Definitions, or Background sections.
City Light has no comments on this section of the BP.
02 Please supply any comments related to the Resource Registration – Resource Eligibility and Timelines section.
Recommend changing the deadline for registering resources to 120 days prior to the forward showing submission date. Requiring registration of resources for QCC 15 months ahead of time is unreasonable and unworkable for most resource development / resource procurement timelines.
03 Please supply any comments related to the Resource Registration – Late Registration of Resources section.
Only allowing 10% of late registered resources appears arbitrary and a barrier for entities to join. City Light suggests allowing 75% of late registered resources.
04 Please supply any comments related to the Resource Registration – Qualifying Resource Aggregation section.
City Light has no comments on this section of the BP.
05 Please supply any comments related to the Resource Registration – Generator Testing section.
City Light has no comments on this section of the BP.
06 Please supply any comments related to the Resource Registration – Operational Testing section.
City Light has no comments on this section of the BP.
07 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.
City Light has no comments on this section of the BP.
08 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.
City Light has no comments on this section of the BP.
09 Please supply any comments related to the Resource Registration – Provision of Test Reports in the FS Submittal section.
City Light has no comments on this section of the BP.
10 Please supply any comments related to the Resource Registration – Testing for Late Registered Resources section.
City Light suggests this section should align with the late registration setion regarding qualifying late resources.
11 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Background section.
City Light has no comments on this section of the BP.
12 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Qualified Resources Included in FS Submittal That Have No QCC Previously Calculated section.
City Light has no comments on this section of the BP.
13 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Thermal Resources section.
City Light has no comments on this section of the BP.
14 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Variable Energy Resources section.
City Light has no comments on this section of the BP.
15 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Energy Storage section.
City Light has no comments on this section of the BP.
16 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hybrid Facilities section.
City Light has no comments on this section of the BP.
17 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Demand Response section.
City Light has no comments on this section of the BP.
18 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hydro Resources section.
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.
19 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Other Resources section.
City Light has no comments on this section of the BP
20 Please supply any comments related to Appendix A.
City Light suggests the following language be added to the end of section regarding Treatment of Cascaded and Coordinated Hydro Systems:
Participants with coordinated cascading hydro systems may use their own methodology for maximizing the combined coordinated cascading hydro system QCC. The PO can request a full explanation of the methodology to for verification purposes.
General Comment
City Light recommends that a table should be added to each business practice.
City Light recommends that any references to other documents contain a link or reference to where those documents can be found.