California Public Utilities Commission Orders Rulemaking to Continue Implementation and Administration of California Renewables Portfolio Standard Program

Strategic Insights -

The California Public Utilities Commission has initiated a rulemaking process to continue implementing and administering the California Renewables Portfolio Standard (RPS) program. The proposed decision aims to approve voluntary allocations and modify the market offer process for the sale of excess renewable resources to lower Power Charge Indifference Adjustment (PCIA) costs. However, various stakeholders, including Pacific Gas and Electric Company (PG&E) and Southern California Edison Company (SCE), have objected to certain provisions in the proposed decision.

Key Takeaways:

  • The California Community Choice Association (CalCCA) has submitted reply comments to the proposed decision, emphasizing the need for significant remedies for investor-owned utility (IOU) violations of the Market Offer process.
  • PG&E and SCE's arguments against removing their "waived claims" language regarding remedies for violations related to Market Offer solicitations should be rejected, as they ignore the unique nature of the Market Offer and the importance of ensuring IOU portfolio optimization is administered effectively and equitably.
  • San Diego Gas & Electric Company's (SDG&E) request to allow IOU employees to transfer between the Market Offer bid and evaluation teams after bids are submitted should be rejected, due to the potential for the IOUs to gain a competitive advantage.
  • The proposed decision should be clarified as requested by SCE to specify that all PCIA-eligible RPS resources left over after the voluntary allocation are available for contracting in the Market Offer as required by Decision 21-05-030.
  • The California Community Choice Association recommends that the Commission remove the requirement that IOUs offer long-term contracts, as this may cause delays in the solicitation beyond the first quarter of 2023.
  • The proposed decision should be clarified to remove the phrase "short-term" to read: "Pacific Gas and Electric Company, Southern California Edison Company, and San Diego Gas & Electric Company are approved to offer 100 percent of their remaining Power Charge Indifference Adjustment eligible short-term contracts in the Market Offer."

Statistics:

  • 24 community choice electricity providers in California are represented by the California Community Choice Association.
  • The proposed decision aims to approve voluntary allocations and modify the market offer process for the sale of excess renewable resources to lower PCIA costs.
  • PG&E and SCE have objected to removing their "waived claims" language regarding remedies for violations related to Market Offer solicitations.

Sources:

  • BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking to Continue Implementation and Administration, and Consider Further Development, of California Renewables Portfolio Standard Program. R.18-07-003
  • CALIFORNIA COMMUNITY CHOICE ASSOCIATION'S REPLY COMMENTS ON THE PROPOSED DECISION APPROVING VOLUNTARY ALLOCATIONS AND MODIFYING MARKET OFFER PROCESS FOR THE SALE OF EXCESS RENEWABLE RESOURCES TO LOWER POWER CHARGE INDIFFERENCE ADJUSTMENT COSTS PURSUANT TO DECISION 21-05-030
  • California Community Choice Association represents the interests of 24 community choice electricity providers in California.