those small amounts of funding. 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 Consideration of Disadvantaged Communities Sierra Club partnered with the California Environmental Justice Alliance (CEJA) and together, contributed significantly to the record on how the Integrated Resource Plans could address the disproportionate impacts that disadvantaged communities face: Sierra Club and CEJA stress the importance of outreach and community engagement and provide specific recommendations for how to structure community outreach and engagement. (Opening Comments of California Environmental Justice Alliance and Sierra Club On Administrative Law Judge’s Ruling Seeking Comment on Staff Proposal on Process for Integrated Resource Planning, pp. 2, 9-11, 54, June 28, 2017; Opening Comments of the All page numbers refer to D. issued February 8, 2018. “In addition, all LSEs who propose to conduct procurement activities either for the development of new resources or re-contracting of existing resources for a period of five years or longer (not including any tariffed or must-take resources required by separately-authorized Commission programs or decisions), must describe their planned activities to conduct outreach and seek input from any disadvantaged communities that could be impacted by the procurement… In subsequent IRP rounds, we expect the LSEs to conduct such outreach prior to finalizing and submitting their IRPs to the Commission and to summarize the feedback received from disadvantaged communities and their representatives in the IRP filings.” (p. 69) “Numerous parties commented on the definition of disadvantaged communities included in the Verified Verified Verified Verified Verified Verified
California Environmental Justice Alliance and Sierra Club on the Proposed Reference Plan and Related Commission Policy Actions, pp. October 26, 2017; Reply Comments of California Environmental Justice Alliance, Sierra Club, and Environmental Defense Fund on the December 28, 2017 Proposed Decision of Commissioner Liane M. Randolph, p. 4, January 22, 2018.) “The meaningful public process with DACs should ideally occur during the development of the LSE plans. Initially, potential solutions for DACs should be driven by community input which should involve integration into existing networks, engaging community leaders, and coordinating local meetings aimed at building upon community expertise.” (Opening Comments of California Environmental Justice Alliance and Sierra Club On Administrative Law Judge’s Ruling Seeking Comment on Staff Proposal on 39, May 2017 IRP Staff Proposal to use the top 25% of the communities as defined in CalEnviroScreen. Parties generally in support of this definition included CEJA, Sierra Club, GRID, Liberty Utilities, ORA, SCE, and SDG&E.” (p. 61) “As proposed by Commission staff, and pursuant to Section 39711 of the Health and Safety Code, for purposes of the requirements of SB 350 to address disadvantaged communities impacts in the IRP process, we will define disadvantaged communities as those that score at or above the 75th percentile in the CalEPA’s CalEnviroScreen 3.0 on a statewide basis.” (p. 66) Though the Commission did not accept all of Sierra Club, CEJA, and EDF’s recommendations, the Commission “modified the definition to include CalEPA’s most recent designation of disadvantaged communities, which includes census tracts not previously represented because of a lack of data. We have also included references to statutes which apply only to IOUs in the context of procurement requirements for renewables and gas-fired generating units in disadvantaged communities.” (p. 157)
Process for Integrated Resource Planning, p. 10, June 28, 2017) Sierra Club and CEJA support a definition of disadvantaged communities that is based on CalEnviroScreen criteria, and discuss statutes that support that definition. (Opening Comments of California Environmental Justice Alliance and Sierra Club On Administrative Law Judge’s Ruling Seeking Comment on Staff Proposal on Process for Integrated Resource Planning, pp. 33-37, June 28, 2017; Opening Comments of the California Environmental Justice Alliance and Sierra Club on the Proposed Reference Plan and Related Commission Policy Actions, pp. October 26, 2017.) Sierra Club, CEJA, and the Environmental Defense Fund (EDF) called for a definition of disadvantaged communities that mirrored the definition the Commission used in previous decisions (Comments of California Environmental Justice Alliance, Sierra Club, and Environmental Defense Fund on the December 28, 2017 38, “We will also require each LSE to address in its individual IRP how it will address impacts on disadvantaged communities.” (p. 66) “We also note that there are specific statutory provisions that apply to IOUs and their procurement activities with respect to avoiding further pollution and providing greater clean generation investments in disadvantaged communities.” (p. 67) “Consistent with these requirements for IOUs, each IOU should, in its IRP, describe how it will apply these preferences when soliciting and selecting projects.” (p. 67) “For load served by resources located in disadvantaged communities (existing owned resources, contracted resources, or planned new resources), we expect disclosure of the following information, at a minimum: annual emissions of GHGs, annual emissions of local air pollutants (nitrogen oxides and particulate matter, at a minimum), and number of annual starts. Emissions reporting shall also include emissions due to cycling, in addition to emissions from normal operation.” (p. 68) “Likewise, for non-emitting
Proposal on Process for Integrated Resource Planning, p. 48, June 28, 2017) Compliance with SB 350 and Other Relevant State Mandates Sierra Club supported the use of enforceable mass-based GHG emission limits for 2030, with interim limits for each LSE: “[T]he Commission should only use the GHG Planning Price in the 2017-18 IRP, because this IRP must establish mass-based limits. For the 2019-20 IRP, CEJA and Sierra Club recommend Staff’s proposed option in which the Commission uses “the 2030 emissions reported in each LSE’s preferred portfolio . . . as the basis for a GHG planning target for that LSE.” (Opening Comments of California Environmental Justice Alliance and Sierra Club On Administrative Law Judge’s Ruling Seeking Comment on Staff Proposal on Process for Integrated Resource Planning, p. 16, June 28, 2017; see also Informal “We also intend to utilize the GHG emissions information reported in each LSE’s IRP, once approved by the Commission, as the basis for a mass-based GHG planning target for that LSE in the next IRP cycle, allowing for necessary adjustments due to (p. 116) While the Commission did not select the 30 MMT Scenario that Sierra Club and CEJA supported, the Commission did commit to reevaluating the target in future cycles. “A number of parties favor the 30 MMT Scenario because it has the most beneficial impact on disadvantaged communities, including CEJA and Sierra Club, IID, Imperial County, and Range. CEJA and Sierra Club state that they would accept the 42 MMT Scenario if it was modified to reflect a true doubling of energy efficiency savings, lower storage costs, and prioritization of disadvantaged communities by focusing on retirement of gas-fired resources to minimize air pollution.” (p. 57) “As recommended by Verified Verified Verified based
Comments of the California Environmental Justice Alliance, Sierra Club, and Environmental Defense Fund on the CPUC’s Staff White Paper On Implementing GHG Planning Targets in the IRP Process, pp. 9-11, November 30, 2016; Informal Reply Comments of the California Environmental Justice Alliance, Sierra Club, And Environmental Defense Fund on the CPUC’s Staff White Paper On Implementing GHG Planning Targets in the IRP Process, pp. 4-5, December 7, 2016; Opening Comments of California Environmental Justice Alliance and Sierra Club On Administrative Law Judge’s Ruling Seeking Comment on Staff Proposal on Process for Integrated Resource Planning, pp. 15-16, 18, 61-63, June 28, 2017) Sierra Club and CEJA recommended using the 30 MMT Scenario in the IRPs to better reflect the mandates from SB 350, SB 32, and Executive Order (Opening several parties, we also intend to revisit this target in each IRP planning cycle.” (p. 58) “[T]he GHG target will point the direction and trajectory that can be adjusted when more information becomes available after each two-year cycle, either through better assumptions, improved analytical modeling functionality, and/or actual procurement experience.” (p. 59) “PacifiCorp will be required to file the IRP they already prepare, with any supplemental information about disadvantaged communities or any other required aspect of SB 350 required in this decision that is not already covered in their IRP filing prepared for those other jurisdictions.” (p. 131) “15. PacifiCorp shall file an Alternative integrated resource plan (IRP) consisting of any IRP submitted to another public regulatory entity within the previous calendar year, and shall also include the information required in Ordering Paragraph 6 of this decision as well as any other requirements of Senate Bill 350 not already covered in its IRP.” (p. 174)
Staff Concept Paper on Integrated Resource Planning, pp. 21-22, 26-27, August 31, 2016; Sierra Club and CEJA support LSEs filing applications that are all consolidated into the IRP proceeding. (Opening Comments of California Environmental Justice Alliance and Sierra Club On Administrative Law Judge’s Ruling Seeking Comment on Staff Proposal on Process for Integrated Resource Planning, p. 52, June 28, 2017) Sierra Club and CEJA support aligning the IRP process with the Transmission Planning Process (TPP). “For the 2018-19 TPP, CEJA and Sierra Club agree that CAISO should use the outputs of the Reference System Plan because at that time, the Reference System Plan will be the only planning document that creates a portfolio for the CAISO-wide system that meets the 2030 GHG limit.” (Opening Comments of California Environmental Justice Alliance and Sierra important to ensure transparency and a public process.” (p. 128) “For practical and administrative reasons, we modify the original staff proposal on the mechanisms of IRP filing. Instead of requiring the filing of separate applications by each LSE, we will require that each LSE file its IRP in this rulemaking proceeding, R.16-02-007, as a “compliance filing” (for purposes of document designation only). In this way, all of the IRPs will automatically be consolidated within this proceeding for our consideration.” (p. 130) “During even-numbered years…the following activities will take place…By December 31, the Commission will adopt a PSP for use in the CAISO TPP commencing in February of the years.” (p. 22) “CEJA and Sierra Club preferred that the Commission wait until after approval of the PSP before investigating out-of-state wind further.” (p. 77) “We will continue to study all of these resource types in the next cycle of IRP, to determine if circumstances and cost/benefit assumptions have changed sufficiently to
assumptions. (Opening Comments of California Environmental Justice Alliance and Sierra Club On Administrative Law Judge’s Ruling Seeking Comment on Staff Proposal on Process for Integrated Resource Planning, June 28, 2017; Sierra Club and CEJA commented that the Commission should improve its analysis of demand side resources. “A key improvement that will need to be made is, as PG&E recommends, “treating demand-side resources as candidate resources to the fullest extent possible.” Right now, distributed resources and locational benefits are not accounted for and not considered as ways to meet demand.” (Reply Comments of California Environmental Justice Alliance and Sierra Club on Administrative Law Judge’s Ruling Seeking Comment on Staff Proposal on Process for Integrated Resource Planning, p. 10, July 12, 2017) Sierra Club and CEJA also comment that the Commission should contained in the modeling. Many comments point to improvements that Commission staff intends to make for the next round of optimization analysis that will likely occur beginning in 2019. Commission staff plans to improve the modeling with the participation of parties as part of a public process, similar to this proceeding, where there are workshops and periodic informal work products.” (p. 51)) “For data updates, staff anticipates modifying assumptions for all resource types based, at least in part, on results from any relevant solicitations, including utility-scale resources and DERs… Staff also anticipates updating the transmission costs and potential, land-use information, system requirements, local capacity requirements, avoided GHG and other air pollutant emissions from other sectors, and avoided GHG emissions related to the gas transmission and distribution system.” (p. 51) “For model functionality updates, staff will explore the following issues…Including all DERs as candidate resources at appropriate levels of aggregation, including energy efficiency, shimmy demand response, BTM PV,
optimize all resources. “Achieving the RPS will require the development of a grid that better integrates renewable resources and developing that grid will require information about how all resources can best serve it. A key component of any future effort should be optimization for demand-side resources as well as supply-side resources.” (Opening Comments of California Environmental Justice Alliance and Sierra Club On Administrative Law Judge’s Ruling Seeking Comment on Staff Proposal on Process for Integrated Resource Planning, pp. 41-42, June 28, 2017) Sierra Club and CEJA support using the Default Scenario as the reliability base case for the CAISO TPP Portfolios. (Opening Comments of the California Environmental Justice Alliance and Sierra Club on the Proposed Reference Plan and Related Commission Policy Actions, pp. October 26, 2017) electric vehicles, and building electrification measures.” (pp. 51-52) “For model functionality updates, staff will explore the following issues…Including all DERs as candidate resources at appropriate levels of aggregation, including energy efficiency, shimmy demand response, BTM PV, electric vehicles, and building electrification measures.” (pp. 51-52) “Calpine, Reid, CEJA/Sierra Club, TransCanyon, and TransWest all agree [with using the Default Scenario as the reliability base case].” (p. 102) “Since the Default Scenario represents the scenario that is reasonably likely to occur based on existing policy, we agree with staff that this is the appropriate one to utilize for the reliability base case for the CAISO’s TPP.” (p. 104)