reflect these CPUCapproved changes. IEPA Comments at 1819. SDG&E IEPA comments that SDG&E's LongTerm PPA appears to only contemplate projects with Full Capacity Deliverability Status (FCDS), which would appear to send a market signal that EnergyOnly (EO) projects won't be considered. IEP recommends SDG&E's Model PPA be modified to clarify which role, if any, EO projects can play in an RPS solicitation. We reject this comment. Deliverability status is being addressed in the LCBF Reform track in this proceeding. A requirement for FCDS was previously denied in D.1104030 (at 20), which clearly allows EO projects to be considered in RPS solicitations. IEPA Comments at 5; LSA Comments at 3; CalWEA Reply Comments at 3. PG&E, SCE, and SDG&E IEPA, LSA and CalWEA argue that the IOUs should be required to excel and exceed SB 350’s targets to take advantage of current economic conditions. Specifically, these parties argue that delaying RPS procurement risks higher ratepayer costs As argued by ORA (Reply Comments at 2), SCE (Reply Comments at 3), and PG&E (Reply Comments at 4), the utilities have already established margins of procurement, without the use of
as tax credits diminish over time. IEPA's analysis (using RPS Calculator v.6.2) demonstrates that the reduction in federal tax incentives between 20192022 increases the levelized costs for solar projects by 25% and wind projects by 13%. In addition, CalWEA argues that the ability to obtain federal tax benefits will greatly improve the economic competitiveness of wind repowers for qualifying facility contracts that are about to expire. bank, and each are in a position to exceed their RPS procurement requirements. Given this, along with the uncertainty associated with longterm market conditions and future load, we will not require the IOUs to increase their procurement obligations beyond the minimum targets established by statute at this time. Joint Utilities (SDG&E, PG&E, and SCE) Comments at 12 ESPs/CCAs The Joint Utilities comment that the modifications to law enacted by SB 350 require all retail sellers to prepare and submit RPS Plans that address the requirements in PU Code 399.13(a)(1) and also require CCAs to As noted by AReM (Reply Comments at 2), the Commission has previously determined that ESPs and CCAs should not be required to follow the exact same steps for RPS
participate in the RPS program subject to the same terms and conditions applicable to electrical corporations. Specifically, the Joint Utilities claim that this requires all retail sellers to file solicitation documentation (as required by 399.13(a)(5) and cost quantification tables. They note that the CPUC doesn't approve solicitation documentation, but assert that this documentation still needs to be filed. implementation purposes as the utilities that are fully regulated by the CPUC (D.0511025, pp. 1213). Further, the Commission has no responsibility for the price reasonableness of ESP procurement, and to regulatory over ESP rates (D.1101026, pp. 2223). Therefore, we will not require CCAs and ESPs to file the solicitation and cost quantification tables, but they are required to include in their RPS procurement plans the remaining requirements of Section 399.13(a)(5). LSA at 3 PG&E and SDG&E LSA comments that uncertainty This issue should be
– which has not been formally vetted or approved by the Commission – is not a determining factor in establishing RPS need or reviewing 2016 RPS Plans. count towards RPS goals, regardless of means of procurement as long as it is consistent with the Commissions procurement and compliance rules. Joint Parties (CBEA, CalWEA, Calpine, the Geothermal Association, and Ormat) Comments at 3 CPUC & LSEs Joint Parties urge the CPUC to take the following actions: that curtailment costs are appropriately factored into LCBF energy valuations; the IOUs to use their economic curtailment rights to avoid negative pricing and to pay for CAISOdirected reliabilityrelated generation reductions due to overgeneration conditions; In the event that curtailment is not managed economically by other Commission jurisdictional This decision defers to the LCBF reform track established by ALJ Simon’s June 22, 2016 Ruling in R.1502020 for handling LCBF reformrelated issues.