The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
Last Week's New Ruling +1
Extension Granted
The California Public Utilities Commission has granted the Natural Resources Defense Council (NRDC) an extension until May 30, 2025.
Administrative Law Judge Ruling
This extension is in response to an Administrative Law Judge Ruling issued on March 6, 2025.
Extension Request
NRDC submitted the extension request on March 18, 2025, in accordance with Rule 11.6, concerning their Supplement to the Notice of Intent to Claim Intervenor Compensation.
Commis...
sion Support
The Commission supports this extension to allow NRDC adequate time to address the information required in the March 6 ruling.
Filing of Ruling
The ruling will be formally filed by the Docket office.
Last Week's New Comments +5
CPUC Proceeding R23-05-018 Update
This update provides an overview of recent comments filed regarding CPUC proceeding R23-05-018, focusing on the adoption of General Order 131-E (GO131-E) through Decision D.25-01-055. Several parties, including utilities, trade groups, and developers, have submitted responses supporting the Commission's decision and addressing various concerns related to the California Environmental Quality Act (CEQA) compliance, the role of the Calif...
ornia Independent System Operator (CAISO), and the expedited review process.
Compliance with CEQA
Role and Responsibilities of CAISO
Consideration of Alternatives
Legal Authority and Interpretation
Expedited Review and Permitting Process
Environmental Review and Local Consultation
This summary represents a sampling of parties' positions on various topics related to CPUC proceeding R23-05-018 and the adoption of GO131-E. The responses collectively support the Commission’s decision, emphasizing compliance with legal standards, the critical role of CAISO, and the importance of expediting transmission development in California.
Last Week's New Comments +9
Overview
This update provides a summary of comments filed on March 27, 2025, by various stakeholders in the California Public Utilities Commission (CPUC) proceeding R21-06-017, which focuses on modernizing the electric grid for a future with high distributed energy resources (DER).
Statewide Data Platform and DER Registry
Last Week's New Comments +5
Overview
This update summarizes comments submitted by various parties regarding the CPUC proceeding R23-01-007, which involves Senate Bill 846 and the potential extension of operations at the Diablo Canyon Power Plant. The comments address funding mechanisms, Volumetric Performance Fees (VPFs), spending restrictions, and oversight processes.
Funding Allocation and Oversight
Last Week's New Comments +13
Overview
A variety of stakeholders submitted comments to the California Public Utilities Commission (CPUC) regarding the Administrative Law Judge's ruling on Flexible Service Connections (FSCs) and the modified Phase 2 schedule for CPUC proceeding R24-01-018. The comments address topics such as expanding FSCs, certification requirements, load profiles, incentive mechanisms, standardization, utility implementation differences, and reporting transparency.
Support for...
Expanding FSCs
UL 3141 Certification Requirement
Load Profiles and Limited Load Profiles (LLPs)
Incentive Mechanisms and Compensation
Consistency and Standardization
Utility Implementation Differences
Reporting and Transparency
Last Week's New Ruling +1
Prehearing Conference Details
A prehearing conference for Rulemaking 25-02-005 will take place on April 7, 2025, at 10:00 a.m. via videoconference, with telephone access available.
Access Information
Access details include a webinar link and phone numbers for participation.
Speaker Information Submission
Parties must email their designated speaker and alternate speaker information, including title, party name, email, and phone number, to Nicholas Bonino and Thomas...
Gutierrez by April 2, 2025. Each party is limited to one speaking representative and one alternate.
Ruling Issuance
This ruling was issued by Administrative Law Judge Jacob L. Rambo on March 21, 2025, in San Francisco, California.
Last Week's New Comments +6
Overview
A range of stakeholders, including labor unions, utility companies, community associations, and advocacy groups, have submitted comments on CPUC proceeding R25-02-005. These comments address various aspects of the proposed updates to the Energy Resource Recovery Account (ERRA) and Power Charge Indifference Adjustment (PCIA) policies, reflecting diverse perspectives on ensuring fairness, accuracy, and stability in the PCIA framework.
PCIA Framework
CalCCA emphasizes the need for fair administration of the PCIA framework to ensure equitable treatment of both bundled and unbundled customers. CUE recommends against adopting a monthly calculation method unless it incorporates all transaction data to reduce rate volatility.
Resource Adequacy Market Price Benchmark (RA MPB) Calculation
TURN highlights significant flaws in the current RA MPB methodology, advocating for the inclusion of both short-term and long-term resource commitments to better reflect procurement costs. Joint IOUs support interim changes to the RA MPB and suggest expanding the dataset used for more comprehensive calculations.
Monthly Procurement Budgets (MPBs)
CUE expresses concerns about the accuracy of MPB estimates when transactions are divided into monthly categories, particularly in high-cost months. CAL ADVOCATES/BONE/CPUC supports the use of monthly MPB values while maintaining market sensitivity rules.
Exclusion of Transactions
Cal Advocates proposes excluding affiliate, swap, and sleeve transactions from RA MPB calculations to prevent market manipulation and ensure accurate market price signals. The Alliance for Retail Energy Markets, Direct Access Customer Coalition (AReM/DACC) also recommends excluding certain transactions to avoid double-counting and misrepresentation of market values.
Affordability and Cost Allocation
CalCCA critiques the current PCIA framework for potentially increasing costs for unbundled customers while benefiting bundled customers. Joint IOUs stress the importance of fairness in cost allocation to prevent bundled service customers from shouldering higher rates compared to departing load customers.
Legal and Methodological Reforms
TURN advocates for comprehensive reforms, including the addition of Renewable Portfolio Standard (RPS) MPB adjustments and the development of imputed RA values for renewable resources. Cal Advocates calls for legal clarity on negative PCIA rates and supports methodological enhancements to improve data modeling and reflect current market conditions accurately.
Support for Proposed Timeline and Process
Joint IOUs endorse the proposed timeline for Track 1 of the OIR and advocate for the inclusion of renewable portfolio considerations in the Resource Adequacy framework. They also support the release of anonymized data to inform future discussions in Track 2.
Data Representation and Modeling
Cal Advocates emphasizes the importance of using a large and diverse dataset to accurately represent market values, proposing the inclusion of data from multiple years to enhance the reliability of MPB calculations. AReM/DACC supports using data from the most recent three years to better reflect current market conditions.
Last Week's New Comment +1
Parties Involved
The Joint Investor-Owned Utilities (IOUs) of California, including PG&E, SDG&E, and SCE, are responding to Alexis Wodtke's Application for Rehearing (AFR).
Background
This response pertains to the California Public Utilities Commission (CPUC) Resolution E-5354, which was issued on February 4, 2025. The resolution involves PG&E's implementation of Income Graduated Fixed Charges (IGFC) as mandated by Decision 24-05-028 and Assembly Bill 205.
Critiq...
ue of Wodtke's AFR
CPUC's Discretion and Compliance
The CPUC has broad discretion in its proceedings, including the determination of appropriate notice and the necessity of hearings. Wodtke's claims about inadequate public notice and the need for evidentiary hearings are refuted, as the advice letter process complied with existing regulations and provided her with a meaningful opportunity to be heard. The CPUC's decisions are based on a well-developed record, and Wodtke's assertions about errors and unreasonable assumptions lack specific evidence of prejudice.
Implementation Timeline
PG&E's implementation of the IGFC structure is scheduled for March 2026, with additional advice letters required to ensure accurate rate calculations. The CPUC's requirement for Tier 3 Advice Letters allows for adequate stakeholder participation and aligns with the approved rate design framework.
Concerns Addressed
Conclusion
Overall, Wodtke's AFR is deemed insufficient, lacking specific legal citations and factual evidence necessary to demonstrate legal error. The Joint IOUs request that the CPUC deny her application based on these grounds.
Last Week's New Comments +7
Overview
This update provides a summary of comments filed on March 20, 2025, by various stakeholders regarding CPUC proceeding R23-01-007. The comments address the implementation of Senate Bill 846, particularly focusing on the extension of operations at the Diablo Canyon Power Plant and the management of Volumetric Performance Fees (VPFs).
Implementation of Senate Bill 846
Coalition of California Utility Employees (CUE) recommends that the Public Utilities...
Commission (PUC) continue to implement SB 846 in accordance with Decision D.23-12-036, allowing Pacific Gas and Electric Company (PG&E) discretion over its VPF compensation. PG&E acknowledges that the Proposed Decision (PD) resolves several issues but identifies errors that need correction to align with statutory guidelines.
VPF Spending and Restrictions
CUE opposes proposals from Utility Reform Network (TURN), California Community Choice Association (CalCCA), and Alliance for Nuclear Responsibility (A4NR) that seek to restrict PG&E's spending of VPF compensation, arguing that these restrictions contradict SB 846 and Decision D.23-12-036. TURN emphasizes the need to prevent PG&E from using VPFs to benefit shareholders, recommending that VPFs be prioritized for energization and wildfire mitigation projects. CalCCA and A4NR advocate for equitable distribution of VPFs, with CalCCA specifically calling for VPF funds to prioritize projects that benefit the largest number of customers and prohibit their use for PG&E’s generating assets.
Application Process for VPF Spending
CUE suggests eliminating the requirement for PG&E to file an application for VPF spending plan approval, advocating instead for an advice letter process to expedite funding for public priorities.
Affordability and Reporting Requirements
Small Business Utility Advocates (SBUA) supports the Commission's focus on affordability but calls for enhanced reporting on small commercial customers benefiting from VPF initiatives. TURN recommends rejecting PG&E's annual VPF compensation report template in favor of a more comprehensive reporting approach. PG&E argues that the PD’s inclusion of affordability and customer benefit metrics violates statutory language and recommends modifications to align with existing provisions.
Equitable Distribution and Participation of Small Businesses
SBUA emphasizes the importance of increasing small business participation in utility programs by identifying gaps and conducting targeted outreach. CalCCA advocates for prioritizing VPF spending on distribution and transmission projects to ensure equitable benefits for all customers, preventing disproportionate costs on small businesses.
Legal Concerns and Statutory Compliance
A4NR criticizes the PD’s reliance on Decision D.23-12-036 for limiting critical public purpose priorities to PG&E’s service territory, arguing it undermines anti-discrimination provisions of Public Utilities Code Section 453. TURN highlights concerns that the PD does not adequately prevent shareholder enrichment and calls for compliance with Section 712.8(s) to ensure VPFs are used for public purposes.
Recommendations for Commission's Guidance and Decision
CUE and CalCCA advocate for maintaining PG&E’s discretion over VPF spending while calling for process revisions to align with legislative intent. TURN suggests adopting its proposals to constrain VPFs for essential capital expenditures and enhancing reporting requirements. PG&E recommends that the Commission evaluate the necessity of ongoing audits and modify findings related to customer benefit metrics to better align with statutory guidelines.
Collaboration and Funding Plans
A4NR emphasizes the need for PG&E to collaborate with SCE and SDG&E to create funding plans for critical public purposes within their respective areas, advocating for a harmonized approach to VPF distribution and utilization.
Prioritization of Projects
CalCCA urges the Commission to prioritize VPF spending on electric distribution and transmission projects, allowing generation project funding only when other options are exhausted to maximize customer benefits and maintain equitable distribution of resources.
Last Week's New Comments +22
Overview
The California Public Utilities Commission (CPUC) is conducting Rulemaking 23-10-011, which focuses on reforms to the Resource Adequacy (RA) Program. Various stakeholders, including utilities, trade associations, and energy providers, have submitted reply comments addressing key aspects such as Planning Reserve Margins (PRM), load obligation trading, and the integration of energy storage resources. This update highlights a sampling of these positions to...
provide a comprehensive view of the ongoing discussions.
Planning Reserve Margin (PRM)
Calpine Corporation supports the proposed PRMs of 21% for June-October and 20% for other months to achieve a 1-in-10 Loss of Load Expectation (LOLE) annually. Southern California Edison Company (SCE) advocates for a 17% PRM, arguing it suffices for reliability and criticizes higher proposals as financially driven. Microsoft Corporation endorses Staff Proposal B, recommending a 22.5% PRM to meet LOLE standards. American Clean Power - California also supports a robust PRM aligned with a 0.1 LOLE, emphasizing reliability.
Load Obligation Trading
The California Community Choice Association (CalCCA) advocates for hourly load obligation trading to enhance affordability and efficiency, proposing a 25% limit with a review after one year. Pacific Gas and Electric Company (PG&E) supports CalCCA’s adjustments and recommends further examination of these limits. The Alliance for Retail Energy Markets (AReM) endorses the proposal, suggesting accountability measures for Load Serving Entities (LSEs) post-trade.
Unforced Capacity (UCAP)
The California Energy Storage Alliance (CESA) calls for developing a UCAP accreditation methodology for thermal power plants and battery storage systems, emphasizing the need for comparable UCAP values across resource types. Microsoft Corporation recommends a structured working group for future LOLE modeling to enhance transparency in UCAP development. Middle River Power LLC (MRP) urges collaboration with CAISO on UCAP and opposes counting Energy-Only resources towards RA requirements.
Resource Sufficiency and Imports
Calpine Corporation expresses concerns that SCE's recommendations may overly rely on non-resource adequacy (RA) imports, potentially jeopardizing the 1-in-10 LOLE objective. The Clean Energy Buyers Association (CEBA) criticizes SCE’s approach to PRM and import reliability, advocating for a robust PRM to meet LOLE standards. California Environmental Justice Alliance (CEJA) emphasizes that relying on imports could undermine reliability and supports maintaining higher PRMs.
Energy Storage Integration
California Energy Storage Alliance (CESA) opposes SCE’s proposal to eliminate interim charging sufficiency for paired resources, advocating instead for a nuanced approach based on duration and efficiency. Microsoft Corporation supports integrating energy storage at its Effective Load Carrying Capacity (ELCC) to align RA value with reliability. Middle River Power LLC (MRP) rejects mandates for Long Duration Energy Storage (LDES) in the RA program, suggesting such discussions occur within the Integrated Resource Planning (IRP) framework.
Methodological Concerns and Reliability Standards
California Independent System Operator Corporation (CAISO) opposes lower PRM justifications, asserting that higher PRMs are necessary for meeting 0.1 LOLE reliability standards. Shell Energy North America (US), L.P. raises concerns about the RA waiver process potentially leading to market distortions. The Center for Energy Efficiency and Renewable Technologies (CEERT) supports UCAP methodologies that align with IRP obligations to ensure reliability without compromising affordability.
Stakeholder Collaboration and Future Planning
CalCCA and The Alliance for Retail Energy Markets (AReM) emphasize the need for ongoing dialogue and collaborative working groups to refine PRM and UCAP methodologies. Cal Advocates/M.Miley/CPUC urges the Commission to adopt broker initiatives and enhance market-driven solutions for co-located resources. San Diego Gas & Electric Company (SDG&E) and other stakeholders call for maintaining the current PRM while supporting further analysis for future adjustments.
Affordability and Cost Mitigation
Microsoft Corporation argues that higher PRMs do not necessarily increase costs and highlights historical instances where low PRMs led to significant price spikes and reliability issues. The California Environmental Justice Alliance (CEJA) counters concerns about PRM affordability by emphasizing the long-term costs of an unreliable grid. Shell Energy North America (US), L.P. supports PRM measures that do not impose additional burdens on ratepayers while maintaining reliability.
