PART II: SUBSTANTIAL CONTRIBUTION: Did the Intervenor substantially contribute to the final decision (see § 1802(j), § 1803(a), 1803.1(a) and D.98-04-059). Intervenor’s Claimed Contribution(s) Specific References to Intervenor’s Claimed Contribution(s) CPUC Discussion Summary In this Rulemaking, originally filed in February 2016, the proceeding began with a significant amount of informal work such as workshops, staff concept papers, scenario developments, modeling advisory groups, and GHG emissions targets for IRP’s. Many parties submitted informal comments including UCAN. A proposed Reference System Plan (RSP) was issued September 2017 and a final decision setting the requirements for LSE IRPs was issued February 2018. UCAN’s examination of the issues focused on the best case scenarios for the most flexible Integrated Resource Plans at the least cost to the Load Serving Entities (LSEs) that could simultaneously achieve State GHG reduction mandates but result in the lowest costs to utility ratepayers. D.18-02-018, p. 4, 9, 2 “This proceeding began with a great deal of informal work by Commission staff and parties. Commission staff circulated informal working papers, conducted webinars and workshops, and sought informal party comments over most of 2016 and the first half of 2017.” (p. 4) “On September 19, 2017, an ALJ ruling was issued formally incorporating the modeling results into the record of the proceeding via attachments to the ruling, and seeking comment on a series of questions embedded in the ruling. This September 19, 2017 ALJ ruling represented the staff recommendation for the Reference System Plan (RSP), proposed to be adopted by the Commission.” (p. 9) “The purpose of this decision is to set requirements for all load-serving entities (LSEs) under the jurisdiction of the Commission to file Integrated Resource Plans (IRPs) on or before June 1, 2018.” (p. 2) Verified Issues Verified
Decision D.18-02-018 sets requirements for the LSEs to file IRPs on or before June 1, 2018. These requirements include several of the concepts offered by UCAN throughout the proceeding, including flexibility for LSE’s when developing individual IRPs and in the adoption of GHG reducing generation, as well as consideration of transmission impacts. “UCAN would like to note that we generally support the process suggested by the PD and we support its attempt to provide load serving entities (LSEs) sufficient flexibility to procure least-cost resources that provide the greatest value to ratepayers.” UCAN Comments on PD, p. 3 1. Flexibility for IOU’s when developing individual IRP’s: UCAN supported flexibility for each LSE to develop their own individual IRP that could meet the required targets rather than “top down” mandated portfolios because this would allow each LSE to contribute to statewide goals as efficiently as possible. Ultimately, the Commission adopted this concept and allowed the individual LSEs flexibility to propose alternate portfolios to the reference system portfolio in addition to conforming portfolios. “The ideal LSE IRP should reflect the least cost energy resource additions in which the LSE controls the timing and type of resources added each year to meet the State’s RPS and GHG mandated goals. Each LSE, developing its least cost IRP, should have the flexibility to meet the required targets and each LSE should be able to contribute to statewide goals as efficiently as possible.” UCAN Comments on CPUC Staff Proposal for Implementing IRP, p. 8 June 28, 2017 “Individual LSEs may be able to identify optimal portfolios to serve their load that differ from the mix identified in the Commission reference system portfolio. LSEs should be given flexibility to propose alternate portfolios to meet their customer needs, in addition to conforming portfolios, while justifying any deviations from the reference portfolio.” D.18-02-018, Findings of Fact #9, p. 161 Verified