Comments on Second Revised Draft Tariff Language (Phase 2b)

Hybrid resources

Comment period
Aug 17, 10:30 am - Aug 20, 05:00 pm
Submitting organizations
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Submitted 08/25/2021, 04:57 pm

Submitted on behalf of
Large-scale Solar Association (LSA) and Solar Energy Industries Association (SEIA).


Susan Schneider (

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

Our comments are mostly clean-up/clarification comments, but we have a few substantive issues, summarized below.  Please see the attached mark-up for additional details.

  • ACC constraint relaxation (tariff Section 27.13):  The conditions for this – i.e., relaxation just before the power-balance constraint, and after the CAISO runs out of bids – should be in the tariff, not just the BPMs.
  • EIM Entity ACC violations (tariff Section 27.13):  Not clear why the conditions for revoking ACC use are different than for CAISO-area resources, i.e., the CAISO should revoke ACC use directly.
  • Hybrid Resource outage reporting (tariff Section  The statement below is unclear - if an outage or de-rate reduces the Hybrid Dynamic Limit, does this mean the outage or de-rate should not be submitted through OMS?  Or, if it’s reported in OMS, the Hybrid Dynamic Limit should not include it?  Perhaps you are trying to address the double-counting issues for UCAP purposes, but this provision needs to be more clearly written.

Scheduling Coordinators should not request outages duplicative of the Hybrid Dynamic Limits.   

  • Flexible Capacity (tariff Section  Major issue.  The draft language says HR EFC generally is the sum of the component EFCs, but the overall limit cannot exceed the NQC.  Since storage usually counts for twice the NQC (the positive and negative range), this would effectively cut the storage NQC in half just because it’s in the same Resource ID as another technology.  Flawed technically and policy-wise; discussed in the stakeholder process, but apparently not corrected.
  • Shared met data (Appendix Q, new Section  Why the added provision prohibiting wind from sharing met data with another facility, while it’s allowed for solar?  And, when was that discussed in the stakeholder process?



2. Provide your organization’s comments on Appendix A:

Please see attachment

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

Please see attachment

4. Provide your organization’s comments on Section 29 (EIM Access; Communications; EIM Settlements; EIM Operations):

Please see attachment

5. Provide your organization’s comments on Sections 30-34 (Market Bidding):

Please see attachment

6. Provide your organization’s comments on Section 40.9.2 (Exemptions):

Please see attachment

7. Provide your organization’s comments on Section 40.10.4 (Effective Flexible Capacity):

Please see attachment

8. Provide your organization’s comments on Appendix F:

Please see attachment

9. Provide your organization’s comments on Appendix K:

Please see attachment

10. Provide your organization’s comments on Appendix Q:

Please see attachment

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