expressing concern that transferring megawatts in and out of the customer grid domain would reduce energy storage procurement in other areas, thereby undermining the energy storage procurement targets. Sierra Club urged the Commission to avoid undercutting the important role served by customer grid domain, and to protect its ability to enhance the integration of rooftop photovoltaic technologies (See Sierra Club Comments on Track 1 Issues at 9, July 8, 2015.) In addition, Sierra Club explained that because “[e]nergy storage powered by renewables on the customer side … provide[s] electricity to customers during the most expensive period, during peak hours …” it plays an important role in addressing concerns related to the “duck curve”; and that “since electricity storage located in the customer domain does not need to move through the transmission system, this electricity does not incur additional transmission line losses.” (See id.) Finally, while “[e]nergy storage devices sited in the customer domain will also have a lower GHG emissions factor compared to one sited at a transmission-level domain,” because there are “existing incentives for customer storage to be deployed, the procurement allocation should remain the same.” (Id. at 9.) customer domain facilitates this goal, the IOUs should be permitted the flexibility to do so. Each of the IOU recommends allowing shifting of megawatts into and out of the customer grid domain and allowing all of customer-connected storage to count toward the storage targets. We find this proposal reasonable, if combined with the ‘floor’ and ‘ceiling’ limits … Specifically, so that customer domain targets are not significantly undercut by a single transmission or distribution project, we establish a minimum floor of 100% deployment in the customer domain (i.e., T&D systems may not be used to fulfill the minimum customer domain targets).” (D. 16-01-032 at 32.)
that the Commission is focused on in this proceeding.” (Sierra Club Reply Comments on Track 2 Issues at 7-8, February 19, 2016.) “Arguments that pertain to the integration of one-way electric vehicles into the State’s renewable energy resource markets should be re-directed to the proceedings in which the Commission is already considering such issues. Providing yet another forum to consider V1G issues can create confusion, further undermining the goal of increasing the deployment of two-way storage resources in this proceeding.” (Id. at 9) transportation planning agencies, automakers, and other electric vehicle experts.” (Id. at 8-9.) “Providing yet another forum to consider V1G issues can create confusion, further undermining the goal of increasing the deployment of storage resources in this proceeding. For this reason, we do not modify our decision to exclude V1G from eligibility to meet the energy storage targets.” (Id.) 5. The Commission Should Not Re-visit its Prior Determination Regarding the Eligibility of Hydrogen Power to Gas (P2G) Resources. “[P2G] technologies may involve creating methane gas, a potent GHG, from renewable energy resources. Combusting this newly created methane in a power plant will increase GHGs emissions; thus, converting clean energy into dirty energy. Similarly, leaks of this methane from storage will also increase GHG emissions. Thus, using [P2G] resources to meet storage procurement targets would jeopardize progress toward the State’s GHG reduction goals, which are explicitly included in the energy storage procurement The Commission sided with Sierra Club and others on the issue of whether to revisit its prior non-eligibility determination for hydrogen P2G resources in D. 17-04-039. “In Track 2 comments CHBC and SoCalGas encourage us to revisit this prior decision while Sierra Club, CESA, and ORA support P2G remaining ineligible when injected into the natural gas pipeline system.” (D.17-04-039 at 11.) “Sierra Club counters that injection of hydrogen into the natural gas pipeline system, or injection of methane created in lieu of hydrogen in order to allow increased storage in the natural gas system, takes clean power and converts it into dirty energy because combusting this converted energy will result in an increase of greenhouse gas emissions.” (Id. at 12.) Verified
Duplication of Effort (§ 1801.3(f) and § 1802.5): Intervenor’s Assertion CPUC Discussion a. Was the Office of Ratepayer Advocates (ORA) a party to the proceeding? Yes Verified b. Were there other parties to the proceeding with positions similar to yours? Yes Verified c. If so, provide name of other parties: California Energy Storage Alliance (“CESA”), Environmental Defense Fund (“EDF”), Green Power Institute (“GPI”), and Clean Coalition. Verified d. Intervenor’s claim of non-duplication: Sierra Club offered a unique perspective throughout the proceeding, continuing its active participation on the energy storage issue from prior proceedings. Sierra Club has been a consistent and active environmental group advocating on issues specifically related to greenhouse gas emission reductions and the importance of integrating renewable energy resources to meet customer and grid reliability demands. While these positions often complement those of other environmental non-profit groups, ratepayer advocates, industry associations, and energy storage companies who participated in the proceeding, Sierra Club represented the interests of its members throughout California, including ratepayers who care deeply about protecting the environment and mitigating the impacts of climate change. Sierra Club members strongly support a rapid transition to an electric grid fueled by renewable energy. Sierra Club’s position on V1G differed with other environmental groups, the Natural Resources Defense Council and the Environmental Defense Fund, in the proceeding. Sierra Club’s comments differed significantly from those offered by the Office of Ratepayer Advocates. Sierra Club coordinated with CESA, EDF, GPI, and Clean Coalition, but submitted its own comments in all instances because it had unique perspectives to offer. This coordination made for a better and more robust record. Noted PART III: REASONABLENESS OF REQUESTED COMPENSATION: General Claim of Reasonableness (§ 1801 and § 1806):
A. Yana Garcia 2016 45.7 $240 $235 plus 1.28% COLA for 2016 = $238, rounded up to $240 $10,968 47.30 [D] $240.00 $11,352.00 A. Yana Garcia 2017 18.5 $245 $240 plus 2.14% COLA, rounded up to $245 $4,533 16.80 [E] $245.00 $4,116.00 Dustin Mulvaney 2015 82.3 $205 D.15-07-026 $16,872 82.25 [F] $205.00 $16,861.25 Dustin Mulvaney 2016 1 $210 $205 plus the 1.28% COLA for 2016 = $207.60, rounded up to $210 $210 1.00 $210.00 $210.00 Adenike Adeyeye 2015 99.8 $145 D.15-07-027; D.15-07-018 $14,471 98.80 [G] $145.00 $14,326.00 Adenike Adeyeye 2016 19.7 $155 $145 plus 5% step increase and 1.28% COLA for 2016 = $154.10, rounded up to $155 $3,054 19.70 $155.00 $3,053.50 [H] Adenike Adeyeye 2017 3.9 $160 $155 plus 2.14% COLA for 2017 = $158.30, rounded up to $160 $624 3.90 $160.00 $624.00 Subtotal: $ 117,268.00 Subtotal: $117,370.75