01 Please supply any comments related to the Introduction, Definitions, or Background sections.
Hybrid Facility: Multiple resources combined using different generating technologies with the same interconnection point.
There's only a few definitions listed but tons of acronyms. Maybe include an acronym table.
02 Please supply any comments related to the Resource Registration – Resource Eligibility and Timelines section.
No response submitted.
03 Please supply any comments related to the Resource Registration – Late Registration of Resources section.
Table 1 - spell out ESR in the description
04 Please supply any comments related to the Resource Registration – Qualifying Resource Aggregation section.
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.
05 Please supply any comments related to the Resource Registration – Generator Testing section.
What is MOD-25? Or include of footnote of where to find this information.
For thermal capability test - why not use historical peformance with temperature data?
Why does thermal have a capability test as well as an operational test as opposed to just an operational test like the rest of the resource technologies?
06 Please supply any comments related to the Resource Registration – Operational Testing section.
ESRs - no metric is included for ESRs. 90% for the consecutive duration seems reasonable in order to ensure it'll perform as expected in a peak event.
07 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.
No response submitted.
08 Please supply any comments related to the Resource Registration – New or Upgraded Unit Testing section.
No response submitted.
09 Please supply any comments related to the Resource Registration – Provision of Test Reports in the FS Submittal section.
No response submitted.
10 Please supply any comments related to the Resource Registration – Testing for Late Registered Resources section.
No response submitted.
11 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Background section.
Table 5 - not a very useful example.
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.
No response submitted.
13 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Thermal Resources section.
No response submitted.
14 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Variable Energy Resources section.
For resources with only synthesized data where PO decides between that and average, seems like VER always underperforms so using the average should be discounted.
15 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Energy Storage section.
What's the justification of using 50% of the 4-hr QCC?
16 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hybrid Facilities section.
No response submitted.
17 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Demand Response section.
If DR is included in load, it effectively receives a 100% QCC and reduces the PRM requirement. New DR only qualifies for QCC based on five continuous hours (so could be less than 100%) and therefore is not equivalent in its capacity benefits. to ensure the greatest reliability, DR should be removed from historical load and the load forecast and only included as a resource? Further the 5 hour method should be replaced with an ELCC approach.
18 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Hydro Resources section.
No response submitted.
19 Please supply any comments related to the Qualifying Capacity Contribution of Resources – Other Resources section.
Need instructions on how to deal with the < 1 MW resources that aren't within 10 miles...
20 Please supply any comments related to Appendix A.
Table A-1 - specific to reservoir elevation range - Should we be modeling physical/license constraints or operational rules?
General Comment
How are forced outages treated? Or is this addressed in another BPM and, if so, which one?
Maintenance outages outages is not included in this document- should it be? If so, how should planned maintenance be considered for outage of 3 days or less (full exclusion or partial capacity reduction?) Also how to consider cascading unit outages at multi unity facilities, where no more than 1 unit is out at a time?