The table below shows the methodology used to calculate each of these risks, and to which category of projects in PG&E’s portfolio the risks apply. More detailed descriptions of each risk are described in the subsections below. Table 6-1 Pacific Gas and Electric Company Deterministic Model Risks RISK METHODOLOGY APPLIES TO Standard Generation Variability For non-Qualifying Facility (QF) projects executed post2002, 100% of contracted volumes For QFs, typically based on an average of the three most recent calendar year deliveries QFs, utility-owned generation (UOG) and IDWA generation projections are updated to reflect the most recent hydro forecast. Online Projects Project Failure In Development projects with high likelihood of failure are labeled “OFF” (0% deliveries assumption) All other In Development projects are “ON” (assume 100% of contracted delivery) In Development Projects Project Delay Professional judgment/Communication with counterparties Under Construction Projects/Under Development Projects/Approved Mandated Programs
6-2 Pacific Gas and Electric Company Categorization of impacts on RPS Position Impact Categorization Retail Sales Variability: Changes in retail sales tend to persist beyond the current year (e.g., economic growth, EE, CCA and direct access (DA), and distributed generation impacts). RPS Generation Variability: Variability in yearly generation is largely an annual phenomenon that has little persistence across time. Variable and persistent (If an outcome occurs, the effect persists through more than one year). Variable and short-term (If an outcome occurs, the effect may only occur for the individual year.) Curtailment: Impact increases with higher penetration of renewables and will be persistent. Variable and persistent Project Failure Variability: Lost volume from project failure persists through more than one year. Variable and persistent Quantitative Information Deterministic Model Results Results from the deterministic model under the 33% RPS target are shown as the physical net short in Row Ga of Appendices C.1a and C.2a of its 2015 RPS Plan, while the results from the deterministic model under the 40% RPS scenario are shown as the physical net short in Row Ga of Appendices C.1b and C.2b. Appendices C.1a and C.1b provide a physical net
Entire RPS Plan Consideration of a Higher RPS Requirement Include response to the Specific Requirements for 2015 RPS Procurement Plans, considering both the current 33% by 2020 target and a 40% by 2024 scenario. Assigned Commissioner’s Ruling (ACR) at pp.5-6. Section 2.1 Commission Implementation of SB 2 (1x) Include discussion of D.1412023, setting RPS compliance and enforcement rules under SB 2 (1X). ACR at p. 4. Section 3.2.2 Impact of Tariff Shared Renewable Program Include discussion of impact of Green Tariff Shared Renewable Program on RPS position. D.14-11-042; D.1501051. Section 3.4 Anticipated Renewable Energy Technologies and Alignment of Portfolio With Expected Load Curves and Durations Include discussion of IC adder as part of LCBF bid evaluation methodology. ACR at p.15. Section 3.5 RPS Portfolio Diversity Include discussion of efforts to increase portfolio diversity. ACR at p.10.
either (1) a negotiated price reduction specific to the project; or (2) the application of “energy only” TOD factors in place of “FCDS” factors until such time as the project is deemed fully deliverable. Economic Curtailment The issue of curtailment is a result of the operational characteristics of the facilities within the renewable market (both those procured pursuant to the RPS program, as well as customer-side facilities). These resources are typically intermittent, which results in generation profiles that do not necessarily sync with load. SDG&E states it does not have a robust set of data with which to perform a detailed economic curtailment analysis at this time because (i) SDG&E does not have the right to curtail the majority of its facilities and the number of such facilities has evolved over time, and (ii) the CAISO’s revisions have been in effect for a little over one year and economic curtailments have only recently begun. However, SDG&E believes that economic curtailment analysis will be possible in the future as contracts are amended to include economic curtailment rights, the updated contracts (attached as Appendices 6, 7, and 11.A to SDG&E’s 2015 RPS Plan) which includes economic curtailment rights is used in further contracting, and as the passage of time yields a more complete set of data. SDG&E anticipates that this data could, for example, potentially be used to forecast curtailment, inform how SDG&E bids energy into the CAISO, and/or enhance the LCBF calculation. Expiring Contracts Appendix 4 to SDG&E’s 2015 RPS Plan lists the contracts in SDG&E’s portfolio, as of June 2015, that will be expiring in the next 10 years.