Ryan Duncan, Washington, DC.
Dear PRC-029-1 Drafting Committee,

We appreciate the opportunity to comment on the Final Draft of PRC-029-1 (Frequency and Voltage Ride-through Requirements for Inverter-Based Resources) and commend the committee's efforts in refining grid reliability standards. As an integrated battery and inverter manufacturer (Megapack) and a recognized Inverter-Based Resource (IBR) supplier, we would like to propose the following additions to enhance system flexibility and grid reliability:

Augmentation Interconnection Language
 - The current standard does not account for the demonstrated lack of adverse impact when adding AC augmentation to existing IBRs. 
 - Recommend an explicit section stating that augmentation of existing AC-coupled IBRs should not trigger a restudy if it does not materially impact performance or grid stability metrics.

Provision for Grid-Forming Capabilities
 - The document focuses on ride-through capability but does not address the role of grid-forming inverters in grid stability.
 - Recommend adding a requirement that new IBRs should have grid-forming capabilities where technically and economically feasible.

Recognition of PV+BESS Hybrid Systems
 - The document separately treats battery energy storage systems (BESS) and wind/PV. 
 - Propose clarifications that hybrid systems (e.g., solar + storage, wind + storage) should be treated as unified resources in compliance assessment to simplify the compliance burden and interconnection process.  

We urge the committee to consider these updates to reduce unnecessary interconnection barriers, promote hybrid system adoption, and enhance the grid’s ability to integrate inverter-based resources effectively.

Sincerely,
Ryan Duncan
Tesla