Maybe, but I'm not convinced. The document that you linked to is draft version and the text is for A.1 Non-residential while the VPP is under A.4 rules. It does say hourly, but it isn't clear to me if that is hour-by-hour comparison or using hourly increments versus 5 or 15 minute increments. Further confusing the issue is the latest
CPUC ELRP documents make reference to "adopted baseline methodology" and "(IIOUs) shall have discretion to determine the proper baseline against which Incremental Load Reductions will be calculated".