The AL provides high-level information on the structure of the PMP. The PMP must demonstrate how the paired-storage system will be operated. The PMP itself is a required document as part of the incentive reservation request. The revised SGIP Handbook details what is to be included in a PMP on pages 46-47 of the proposed draft. Many of these requirements are pre-existing and would be familiar to many SGIP developers. New, apparently additional, requirements are mentioned for paired-storage systems. These are: The anticipated charge and discharge schedule of the system demonstrating that the system complies with ITC operational requirements or, for projects not claiming the ITC, will be charged at least 75% from renewables; The metering that will be used to verify that the system is being charged from renewables; The ability to provide data to verify operation in the event of an audit. In its protest SolarCity argues that these bulleted requirements are vague and leave underlying detail undefined. SolarCity is concerned about potential gaming, and recommends more stringent PMP requirements be adopted to ensure that the 75% renewable charging requirement for paired-storage systems is met. Custom Solar argues that the third bullet cited above is too vague and needs to be more specific as to the information that needs to be documented in the event of an audit, and the length of time during which the information should be retained. In their reply, the PAs state that to the diversity of storage technologies and “due configurations, as well as the minimal experience the program has with verifying storage charging from renewables, the PAs did not develop overly-prescriptive Preliminary Monitoring Plan requirements.” With respect to Custom Power Solar’s argument, the PAs state that “[s]torage systems must be able to monitor the energy and power of charging and discharging and the number of charges and discharges in no greater than fifteen-minute intervals. Systems must have the ability to meter, monitor, and
The AL provides high-level information on the structure of the PMP. The PMP must demonstrate how the paired-storage system will be operated. The PMP itself is a required document as part of the incentive reservation request. The revised SGIP Handbook details what is to be included in a PMP on pages 46-47 of the proposed draft. Many of these requirements are pre-existing and would be familiar to many SGIP developers. New, apparently additional, requirements are mentioned for paired-storage systems. These are: The anticipated charge and discharge schedule of the system demonstrating that the system complies with ITC operational requirements or, for projects not claiming the ITC, will be charged at least 75% from renewables; The metering that will be used to verify that the system is being charged from renewables; The ability to provide data to verify operation in the event of an audit. In its protest SolarCity argues that these bulleted requirements are vague and leave underlying detail undefined. SolarCity is concerned about potential gaming, and recommends more stringent PMP requirements be adopted to ensure that the 75% renewable charging requirement for paired-storage systems is met. Custom Solar argues that the third bullet cited above is too vague and needs to be more specific as to the information that needs to be documented in the event of an audit, and the length of time during which the information should be retained. In their reply, the PAs state that “due to the diversity of storage technologies and configurations, as well as the minimal experience the program has with verifying storage charging from renewables, the PAs did not develop overly-prescriptive Preliminary Monitoring Plan requirements.” With respect to Custom Power Solar’s argument, the PAs state that “[s]torage systems must be able to monitor the energy and power of charging and discharging and the number of charges and discharges in no greater than fifteen-minute intervals. Systems must have the ability to meter, monitor, and