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A22-05-022

+21

New comments

Application of PACIFIC GAS AND ELECTRIC COMPANY (U39E) for Review of the Disadvantaged Communities – Green Tariff, Community Solar Green Tariff and Green Tariff Shared Renewables Programs.

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Renewable Energy Programs Update

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:

Overview of Renewable Energy Programs

The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.

Comments on Proposed Decision

The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).

FERC Orders and Cases

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.

Treatment of Credits

The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.

Solar for All Program and National Community Solar Partnership

The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.

Potential Modifications to the NVBT

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.

Recommendations for the NVBT Program

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.

Use of Funding Sources

Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.

Targeting Low-Income Households

Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.

Challenges with PURPA Prices

Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.

Stakeholder Comments

Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.

Concusion

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.

AB-2083

+21

New comments

Bill to cut California's industrial emissions, shift to zero-emission tech, and prioritize disadvantaged communities by 2045

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Renewable Energy Programs Update

Overview of Renewable Energy Programs

The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.

Comments on Proposed Decision

The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).

FERC Orders and Cases

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.

Treatment of Credits

The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.

Solar for All Program and National Community Solar Partnership

The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.

Potential Modifications to the NVBT

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.

Recommendations for the NVBT Program

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.

Use of Funding Sources

Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.

Targeting Low-Income Households

Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.

Challenges with PURPA Prices

Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.

Stakeholder Comments

Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.

Concusion

AB-3246

+21

New comments

Streamline approval process for upgrading transmission facilities by allowing advanced reconductoring projects without construction permits, reducing costs and improving efficiency

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Renewable Energy Programs Update

Overview of Renewable Energy Programs

The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.

Comments on Proposed Decision

The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).

FERC Orders and Cases

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.

Treatment of Credits

The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.

Solar for All Program and National Community Solar Partnership

The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.

Potential Modifications to the NVBT

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.

Recommendations for the NVBT Program

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.

Use of Funding Sources

Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.

Targeting Low-Income Households

Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.

Challenges with PURPA Prices

Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.

Stakeholder Comments

Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.

Concusion

A22-05-022

+21

New comments

Application of PACIFIC GAS AND ELECTRIC COMPANY (U39E) for Review of the Disadvantaged Communities – Green Tariff, Community Solar Green Tariff and Green Tariff Shared Renewables Programs.

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Renewable Energy Programs Update

Overview of Renewable Energy Programs

The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.

Comments on Proposed Decision

The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).

FERC Orders and Cases

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.

Treatment of Credits

The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.

Solar for All Program and National Community Solar Partnership

The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.

Potential Modifications to the NVBT

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.

Recommendations for the NVBT Program

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.

Use of Funding Sources

Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.

Targeting Low-Income Households

Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.

Challenges with PURPA Prices

Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.

Stakeholder Comments

Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.

Concusion

AB-2083

+21

New comments

Bill to cut California's industrial emissions, shift to zero-emission tech, and prioritize disadvantaged communities by 2045

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Renewable Energy Programs Update

Overview of Renewable Energy Programs

The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.

Comments on Proposed Decision

The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).

FERC Orders and Cases

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.

Treatment of Credits

The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.

Solar for All Program and National Community Solar Partnership

The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.

Potential Modifications to the NVBT

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.

Recommendations for the NVBT Program

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.

Use of Funding Sources

Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.

Targeting Low-Income Households

Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.

Challenges with PURPA Prices

Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.

Stakeholder Comments

Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.

Concusion

AB-3246

+21

New comments

Streamline approval process for upgrading transmission facilities by allowing advanced reconductoring projects without construction permits, reducing costs and improving efficiency

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Renewable Energy Programs Update

Overview of Renewable Energy Programs

The NVBT and community solar projects are at the forefront, with discussions on their potential to expand renewable energy access.
Criticisms target the Avoided Cost Calculator (ACC) for not fully recognizing the benefits of NVBT and potentially undermining renewable energy efforts.

Comments on Proposed Decision

The Coalition for Community Solar Access expresses concerns about the proposed decision not aligning with Assembly Bill 2316 and the potential cost shifts to nonparticipating customers.
Solar Landscape Origination LLC criticizes Pacific Gas and Electric Company's green tariff programs, suggesting modifications to better serve low-income households and increase the capacity of the Disadvantaged Communities Green Tariff Program (DAC-GT).

FERC Orders and Cases

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.

Treatment of Credits

The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.

Solar for All Program and National Community Solar Partnership

The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.

Potential Modifications to the NVBT

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.

Recommendations for the NVBT Program

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.

Use of Funding Sources

Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.

Targeting Low-Income Households

Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.

Challenges with PURPA Prices

Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.

Stakeholder Comments

Valta Energy and The Clean Coalition support the NVBT for its potential to democratize access to solar energy and promote equitable distribution of economic benefits.
Concerns are raised about the commercial viability of the Community Renewable Energy Program (CREP) and the adequacy of compensation under PURPA’s framework.

Concusion

R24-01-017

2 Comments

Order Instituting Rulemaking to Continue Implementation and Administration, and Consider Further Development, of California Renewables Portfolio Standard Program.

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Last Week's New Comments +2

CPUC R24-01-017: Sampling of Parties' Positions on Proposed Decision for 2025 RPS Plans

The California Public Utilities Commission (CPUC) proceeding R24-01-017 addresses the Proposed Decision (PD) on 2025 Renewables Portfolio Standard (RPS) Procurement Plans. Recent comments from a sampling of parties highlight ongoing disputes over the valuation of pre-2019 banked renewable energy credits (RECs), cost allocation, and compliance with ratepayer indifference laws....

Parties also address the need for regulatory clarity and flexibility in procurement planning.

Support for Proposed Decision and Requests for Clarification

SDCP and CEA support approval of the PD but urge clarification regarding the valuation of banked RECs generated before 2019.
PG&E generally supports the PD, noting alignment with affordability and compliance goals, but requests modifications to allow short-term RPS procurement and seeks clarification on the effective date of the Final 2025 RPS Plans.

Valuation and Cost Allocation of Pre-2019 Banked RECs

SDCP and CEA emphasize that the valuation of pre-2019 banked RECs remains contentious, with disputes over cost allocation between bundled and unbundled customers under California’s Indifference Framework. They stress that any cost savings from banked RECs must comply with state law and be credited to departed customers.
PG&E argues that assigning a zero value to pre-2019 banked RECs benefits bundled customers, allowing use of credits without compensating departed customers who originally paid for them. PG&E warns that requiring payments for these RECs could increase customer costs and undermine affordability objectives.

Recommendations for Decision Language and Process

SDCP and CEA recommend that the PD avoid prejudging unresolved controversies and revise its language for clarity, fairness, and equity in customer treatment.

RPS Compliance and Affordability

PG&E states that it can meet RPS compliance and maintain affordability using current RPS-eligible resources and banked credits, unless required to make payments to departing load customers for pre-2019 RPS bank usage. PG&E notes that the Draft 2025 RPS Plan’s affordability analysis is incomplete if such payments are mandated.

CPUC Approval and Next Steps

PG&E is authorized by the CPUC to conduct both short-term and long-term RPS resource procurement, provided affordability is demonstrated. PG&E may begin solicitations for RPS volumes after submitting its Final 2025 RPS Procurement Plans, unless suspended by the Energy Division.

Order Instituting Rulemaking to Continue Implementation and Administration, and Consider Further Development, of California Renewables Portfolio Standard Program.

R18-07-006

11 Comments

Order Instituting Rulemaking to Establish a Framework and Processes for Assessing the Affordability of Utility Service.

OIR

Scoping Memo

Proposed Decisions

Final Decisions

Closed

Last Week's New Comments +11

CPUC R18-07-006: Recent Comments on Proposed Decision to Update Affordability Framework

The California Public Utilities Commission (CPUC) received a range of comments on its Proposed Decision (PD) to update the affordability framework for utility services and close the proceeding. This update summarizes a sampling of parties' positions on key topics addressed in the latest filings.

Scope and Timing of Affordability Metrics Implementation

Pacific Gas and...

Electric Company (PG&E)

Bear Valley Electric Service, Inc. (BVES) requests exemption from implementing the new Affordability Framework in its 2027-2030 GRC due to staffing constraints and timing, proposing implementation in the 2031-2034 cycle instead.
California Community Choice Association (CalCCA) recommends expanding the criteria to include any proceeding that could lead to rate increases, not just GRCs, to ensure comprehensive affordability assessment.
Small Business Utility Advocates (SBUA) urges the CPUC to keep the proceeding open or initiate a new rulemaking to develop specific affordability metrics for small businesses, highlighting that current plans do not address their needs.

Reporting Requirements and Data Presentation

PG&E recommends clarifying ambiguous language in the PD regarding which GRC cycles should be included in affordability metric reporting and advocates for narrowing applicability to qualifying GRC proceedings.
CalAdvocates/Bawa/CPUC supports requiring utilities to provide quantitative summaries of rate changes and recommends presenting average rates in GRC applications without including the California Climate Credit for greater transparency.
California Broadband & Video Association (CalBroadband) objects to the elimination of the annual report requirement and warns against posting potentially flawed affordability tools online.
San Diego Gas & Electric Company (SDG&E) and Southern California Gas Company (SoCalGas) oppose the new requirement to include additional graphical information with affordability metrics, arguing it lacks record support and could undermine established metrics.
Southern California Edison Company (SCE) criticizes the requirement for graphical comparisons of GRC revenue requirements and rate growth to inflation, stating these could be misleading without proper adjustments and recommends using System Average Rates for a more comprehensive view.

Confidentiality and Data Accuracy

SCE argues that the PD incorrectly denied its request for confidential treatment of bundled service customer forecast sales data, citing legal and factual errors and potential harm to customers.
CalBroadband contends that the PD relies on outdated data regarding broadband competition and calls for the use of current FCC data to accurately reflect market conditions.

Affordability Metrics Criteria and Contextual Data

CalCCA supports the requirement for investor-owned utilities to provide contextual data alongside affordability metrics to enhance understanding of cost recovery impacts.
CalAdvocates/Bawa/CPUC and other stakeholders emphasize the need for additional context with affordability metrics to avoid misrepresenting impacts, especially for low-income and disadvantaged customers.
CalBroadband recommends revising the Affordability Analysis Criteria (AAC) metric, arguing it misclassifies affluent areas and opposes including housing costs in communications affordability analysis.

Small Business and Vulnerable Customer Considerations

SBUA highlights that small commercial ratepayers face affordability challenges similar to residential customers and lack resources to manage rising costs, urging explicit recognition and tailored metrics for small businesses.
CalCCA notes that the current framework fails to capture broader impacts on vulnerable populations and recommends modifications to better protect these customers.

Procedural and Legal Concerns

SDG&E and SoCalGas assert that introducing new graphical requirements violates their right to meaningful participation and improperly delegates authority to the Energy Division Director without proper procedural framework.
CalBroadband identifies procedural errors in the PD’s approach to defining “essential” communications service and recommends that changes be addressed in a separate proceeding.

Recommendations for Future Actions

CalCCA urges the Commission to outline clearer next steps and concrete actions to address affordability and contain costs, noting the PD lacks specific guidance on future measures.
SBUA and the Commission propose convening a working group to develop small business affordability metrics, with a new rulemaking planned by March 2026.
CalBroadband supports ongoing production of affordability metrics and tools, such as interactive maps, while maintaining AACs for energy, gas, and water stakeholders.

Order Instituting Rulemaking to Establish a Framework and Processes for Assessing the Affordability of Utility Service.

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