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Silicon Valley Clean Energy Advocates for Reliable and Clean Power Procurement Program Framework

Strategic Insights

— 2 min read

The California Public Utilities Commission is facing a critical decision on the future of the Reliable and Clean Power Procurement Program (RCPPP), which aims to ensure a reliable and clean electricity sector. Silicon Valley Clean Energy (SVCE) has submitted a comprehensive set of reply comments advocating for the adoption of Option I, which utilizes Slice of Day (SOD) accounting, as the preferred RCPPP reliability framework. SVCE argues that this approach will provide regulatory certainty to load-serving entities (LSEs) and enable them to make informed procurement decisions.

Key Takeaways:

  • SVCE advocates for the adoption of Option I, which utilizes SOD accounting, as the preferred RCPPP reliability framework.
  • Adopting Option I will provide regulatory certainty to LSEs, enabling them to make informed procurement decisions and ensure a reliable and clean electricity sector.
  • SVCE opposes the issuance of an additional procurement order, citing concerns about its necessity and potential impact on LSEs.
  • SVCE cautions the Commission against using outdated models and methodologies, such as those used in the 2022 IRPs, and instead recommends the use of current system dynamics.
  • The Commission should adopt an RCPPP Framework in the near-term to provide regulatory certainty to market participants, allowing for orderly ongoing procurement and minimizing the risk of LSE leaning.
  • Adoption of Option I with SOD accounting and a Clean Energy Standard (CES) for GHG-reduction would provide a framework that is already largely known and understood, with relatively clear rules for currently commercial technologies.
  • SVCE supports the adoption of a CES framework in the near-term to provide regulatory certainty to LSEs and developers, allowing them to make informed decisions about procurement and resource planning.

Statistics:

  • The 2022 IRPs modeling results are fundamentally out of date and do not represent current system dynamics.
  • The Preferred System Plan (PSP) RESOLVE results suggest that the model was not binding on resource adequacy or the renewables portfolio standard in 2030.
  • The majority of parties who advocated for an additional near-term procurement order provided limited evidence it was necessary to achieve clean goals or maintain reliability.
  • SGDE's proposed procurement order methodology is problematic, as it creates conditions for LSE leaning, allowing LSEs to lean on other LSEs with more aggressive goals.

Sources:

  • Maren Wenzel, Director of Regulatory Policy and Planning, Silicon Valley Clean Energy Authority
  • Silicon Valley Clean Energy (SVCE) Reply Comments on Administrative Law Judge's Ruling Seeking Comments on Reliable and Clean Power Procurement Program Staff Proposal
  • California Public Utilities Commission (CPUC)
  • Order Instituting Rulemaking to Continue Electric Integrated Resource Planning and Related Procurement Processes. Rulemaking 20-05-003 (Filed May 7, 2020)
  • Pacific Gas and Electric Company (PG&E)
  • San Diego Gas and Electric Company (SDG&E)
  • American Clean Power - California (ACP-CA)
  • Solar Energy Industries of America (SEIA)
  • Large-scale Solar Association (LSA)
  • Union of Concerned Scientists (UCS)
  • Natural Resource Defense Council (NRDC)
  • GreenGenStorage, LLC (GreenGen)

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