Comments on Draft Tariff Language

1. 1. Please provide a summary of your organization’s comments on the draft tariff language:

AWEA suggests a number of modifications and reconsiderations of the proposed tariff language. Most importantly, the CAISO should clarify that the Dynamic Limit Tool is an optional tool for Hybrids.  CAISO should clarify that Hybrid Dynamic Limits should generally be based on operating capabilities, but that they can be utilized to address other operational needs, such as restriction of grid charging. The ability to prevent unwanted grid charging for purposes of avoiding Investment Tax Credit recapture was one of the primary drivers of many stakeholders’ interest in the Hybrid resource participation model and the stakeholder process certainly implied that the Dynamic Limit Tool could be utilized to address grid charging restrictions. The tariff language should be modified to ensure the Dynamic Limit tool can, in fact, be utilized in this manner.

2. 2. Provide your organization’s comments on Section 4 (Storage Operating Characteristics; Hybrid Resources):

3. 3. Provide your organization’s comments on Section 30.5.6.1, Hybrid Resource Bids:

During the stakeholder process, the Dynamic Limit Tool was represented as a voluntary tool which Hybrid Scheduling Coordinators could choose to utilize. The language in this section should reflect the optional nature of the tool.

Additionally, this section currently states that: “Hybrid Dynamic Limits must be based on operating capabilities such as State of Charge and resource forecast.” CAISO should modify the language in Section 30.5.6.1 to provide more flexibility in how Hybrid Dynamic Limits can be used in order to ensure they can be utilized to address grid charging restrictions during the ITC recapture period.

4. 4. Provide your organization’s comments on Section 31.2, Day-Ahead MPM Process:

5. 5. Provide your organization’s comments on Section 34 (Mitigating Bids in the RTM; Hybrid Resources; Co-located Resources and Dispatch Instructions):

With respect to section 34.13.3, modifications are necessary to provide clarity. AWEA generally supports the LSA’s comments and revisions to this section. In particular, CAISO must clarify that Co-Located Resources that are Non-Generator Resources are only prevented from deviating from Dispatch Instructions in intervals in which they are providing Ancillary Services.

6. 6. Provide your organization’s comments on Section 40 (Exemptions; Effective Flexible Capacity)

AWEA requests that CAISO clarify the proposed restriction on Hybrid resources’ Effective Flexible Capacity value, specifically, the reasoning for limiting the EFC to a Hybrid Resource’s Net Qualifying Capacity despite the ability of storage to count as EFC for its full range from charge to discharge.

7. 7. Provide your organization’s comments on Appendices A (High Sustainable Limit; Hybrid Dynamic Limit), F (Schedule 4) and K (Part A):

8. 8. Provide any additional comments on the draft tariff language. Upload redlined tariff language using "attachments" field below:

1. 1. Please provide a summary of your organization’s comments on the draft tariff language:

Please see attached mark-up.  Among other things, EDF-R, LSA, and SEIA are concerned about:

(1) Implications that use of the Hybrid Resource Dynamic Limit Tool is mandatory, contrary to the CAISO's proposal documents;

(2) Requirement that the storage-flexibility element (where storage Co-located Resources can deviate from Dispatch Instructions to accommodate additional real-time VER Co-located Resource production) must be incorporated into the POI output-limit scheme instead of subject to communications between the two associated Co-located Resources, by means of their choice, as stated in the CAISO's proposal documents; and

(3) Limitation of Hybrid Resource Effective Flexible Capacity to the sum of the component NQCs, even though storage EFC can exceed NQC (and, therefore, the Hybrid Resource EFC can exceed the sum of the component NQCs).

2. 2. Provide your organization’s comments on Section 4 (Storage Operating Characteristics; Hybrid Resources):

Please see attached mark-up.

3. 3. Provide your organization’s comments on Section 30.5.6.1, Hybrid Resource Bids:

Please see attached mark-up.

4. 4. Provide your organization’s comments on Section 31.2, Day-Ahead MPM Process:

Please see attached mark-up.

5. 5. Provide your organization’s comments on Section 34 (Mitigating Bids in the RTM; Hybrid Resources; Co-located Resources and Dispatch Instructions):

Please see attached mark-up.

6. 6. Provide your organization’s comments on Section 40 (Exemptions; Effective Flexible Capacity)

Please see attached mark-up.

7. 7. Provide your organization’s comments on Appendices A (High Sustainable Limit; Hybrid Dynamic Limit), F (Schedule 4) and K (Part A):

Please see attached mark-up.

8. 8. Provide any additional comments on the draft tariff language. Upload redlined tariff language using "attachments" field below:

Please see the attached mark-up.

1. 1. Please provide a summary of your organization’s comments on the draft tariff language:

PG&E is generally supportive of the Hybrid Resources Draft Tariff language, but has two clarification questions/comments on the following subjects:

• Non-generator Resource deviation from Dispatch Instruction
• High Sustainable Limit in Appendix K

2. 2. Provide your organization’s comments on Section 4 (Storage Operating Characteristics; Hybrid Resources):

3. 3. Provide your organization’s comments on Section 30.5.6.1, Hybrid Resource Bids:

4. 4. Provide your organization’s comments on Section 31.2, Day-Ahead MPM Process:

5. 5. Provide your organization’s comments on Section 34 (Mitigating Bids in the RTM; Hybrid Resources; Co-located Resources and Dispatch Instructions):

In Section 34.13.3, the CAISO describes a situation where an Non-Generator Resource (NGR) deviates from Dispatch Instruction (emphasis added): 

“A Co-located Resource that is a Non-Generator Resource may deviate from a Dispatch Instruction by consuming additional Energy where a co-located Eligible Intermittent Resource is producing above its Dispatch Operating Target due to meteorological conditions such that its output would exceed the Interconnection Service Capacity of the Co-located Resources, or otherwise threaten reliability or safety.”

PG&E understands this as the situation where a co-located Eligible Intermittent Resource (EIR) has a capacity greater than the interconnection limit, and the NGR is already receiving a Dispatch Instruction to charge. By “consuming additional Energy”, the NGR deviates by increasing its charging amount. PG&E offers another potential scenario with different assumptions—if both the EIR and NGR are generating, and the interconnection limit is reached, could the NGR deviate down (lower its discharge) to allow for more EIR generation? This scenario could occur regardless of whether the EIR has a capacity greater than the interconnection limit. However, the “consuming additional Energy” scenario can only occur when the EIR’s capacity exceeds the interconnection limit on its own (e.g. without the additional NGR capacity).

6. 6. Provide your organization’s comments on Section 40 (Exemptions; Effective Flexible Capacity)

7. 7. Provide your organization’s comments on Appendices A (High Sustainable Limit; Hybrid Dynamic Limit), F (Schedule 4) and K (Part A):

PG&E recommends the following edit to the draft tariff language in Appendix K (Part A), considering that the High Sustainable Limit is only applicable to the generation portion of the Hybrid Resource:

• The maximum instantaneous ability, e.g.,. High Sustainable Limit, to produce (e.g. High Sustainable Limit) or consume Energy in MW;

8. 8. Provide any additional comments on the draft tariff language. Upload redlined tariff language using "attachments" field below: