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Weekly Digest
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.
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.
Bill to cut California's industrial emissions, shift to zero-emission tech, and prioritize disadvantaged communities by 2045
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.
Streamline approval process for upgrading transmission facilities by allowing advanced reconductoring projects without construction permits, reducing costs and improving efficiency
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.
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.
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.
Bill to cut California's industrial emissions, shift to zero-emission tech, and prioritize disadvantaged communities by 2045
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.
Streamline approval process for upgrading transmission facilities by allowing advanced reconductoring projects without construction permits, reducing costs and improving efficiency
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.
Order Instituting Rulemaking to Modernize the Electric Grid for a High Distributed Energy Resources Future.
Last Week's New Comment +1
The Green Power Institute (GPI) supports the Proposed Decision's overall direction, including the statewide DER orchestration framework, open communication protocols, and the Load Flexibility Scenario. GPI requests corrections on three errors before adoption, plus technical fixes, all grounded in the existing record.
Phasing and Readiness
- GPI The PD's Section 7.2 contradicts itself on phasing, conflating phased implementation with technology investment cost recovery. GPI...
- recommends deleting the Cal Advocates sentence or clarifying that phased implementation belongs in the Joint IOU Application while technology recovery stays in the GRC, preserving GRC review of technology investments.
- GPI OP 30's alternative readiness standard allowing "soon to be acquired" capabilities contradicts COL 29's proven-capability standard. GPI recommends deleting it, while allowing existing or previously authorized pilots as evidence, and recommends conforming OP 30 to the proven-capability readiness standard in COL 29.
- GPI The PD's cost test is asymmetric, limiting benefits to "measurable" and "applicable" items. GPI recommends modifying COL 14 and OP 15 to require methodologies that distinguish permanent avoidance from deferral of distribution investments, account for the present value of avoided or deferred revenue requirements, treat established Commission tools as measurable, and evaluate cumulative effects.
- GPI The working group's ten topics omit DSO functional roles. GPI recommends adding DSO functional roles as an eleventh topic.
- GPI recommends Energy Division consultation on the facilitator's scope of work and serving the draft report on the service list.
- GPI identifies errors including FOF 24 citing Resolution E-5144 instead of E-5414, OP 13 duplicating OP 24, and typographical errors at PD page 40 and OP 36.
Order Instituting Rulemaking to Refine the Risk Based Decision Making Framework for Electric and Gas Utilities.
Last Week's New Rulings +2
Two October rulings address the Joint IOUs’ responses to Safety Policy Division data requests on risk tolerance. The October 8 ruling set requirements for seeking an extension; the October 13 tentative ruling partially granted the utilities’ extension request and established different schedules for PG&E and the other three utilities.
Extension request requirements
- The October 8 ruling required the Joint IOUs to support an extension request with a motion under Commission...
- Rule 11.1, specifying the action sought and the reasons for the request separately for each utility.
- Joint IOUs The motion was due by noon on October 12, 2026. Responses to the motion were due by noon on October 14, 2026.
- Joint IOUs Any utility able to meet the existing October 12 deadline was directed to provide timely responses. The ruling encouraged utilities to meet that deadline where possible.
- SCE, SDG&E, and SoCalGas These utilities may meet with SPD staff and provide the requested data in full by October 22, 2026. They must file and serve their responses by October 28, 2026, and identify any differences between the data provided to SPD on October 22 and the filed and served responses.
- PG&E must file and serve all responsive data by October 14, 2026, as proposed, or by October 16 if the data is not yet ready, also as proposed. It must immediately provide the other three utilities with details on how it developed its data if they request them.
- West Coast Gas Company, Inc. (WCG) Agrees to use the ruling’s Excel spreadsheet for annual reporting of authorized capital or expense revenue redirected to other purposes, as required by Public Utilities Code Section 591. WCG also agrees to submit an annual Tier 1 Advice Letter when no such revenue was redirected.
- California Association of Small and Multi-Jurisdictional Utilities (CASMU) States that its member utilities are not subject to RAMP requirements and do not file RAMP applications. CASMU reserves the right to address the proposed schedule changes later if they affect or are intended to apply to its members.
Order Instituting Rulemaking to Continue Oversight of Electric Integrated Resource Planning and Procurement Processes.
Last Week's New Ruling +1
An Administrative Law Judge’s Ruling was issued on August 31, 2026, seeking comments on proposed electricity resource portfolios for the California Independent System Operator’s 2027-2028 Transmission Planning Process.
Purpose and Context
This ruling invites a further round of comments on the preliminary mapping of resources to busbars on the transmission system. No reply comments are sought.
Webinar and Materials
- Commission staff are conducting a webinar on October 22,...
- 2026, previously noticed in this proceeding, to explain and discuss the preliminary busbar mapping results.
- Detailed busbar mapping information is available on the Commission’s website at the link provided in the ruling.
- Southern California Edison Company Reply comments, this week: Supported the 38/30 MMT targets for planning, citing build-rate feasibility and cost, and opposed forcing offshore wind into the base case.
- Pacific Gas and Electric Company Reply comments, this week: Supported 38/30 MMT targets for the TPP and Preferred System Plan, citing affordability and feasibility under current planning assumptions.
- San Diego Gas & Electric Company Reply comments, this week: Supported the 38/30 MMT trajectory and a base case without forced offshore wind, while opposing targeted procurement on the current record.
- Environmental Defense Fund Reply comments, this week: Urged retaining 30/25 MMT targets and 4.5 GW of offshore wind, arguing the proposed reductions understate climate and transmission benefits.
- American Clean Power - California Reply comments, this week: Opposed relaxing GHG targets and urged restoring offshore wind, out-of-state wind and conventional geothermal quantities from the prior base case.
- Redwood Coast Energy Authority,County of Humboldt Reply comments, this week: Urged retaining 4.5 GW of offshore wind in the base case, or including it in a sensitivity, and studying North Coast transmission needs.
- Solar Energy Industries Association,Large-scale Solar Association Reply comments, this week: Did not oppose higher GHG targets under the 2024 forecast, but said the Commission should not raise them if it uses the 2025 forecast.
- Middle River Power LLC Reply comments, this week: Supported the proposed 38/30 MMT targets as a more achievable planning trajectory consistent with the 2045 goal.
- Mussey Grade Road Alliance Reply comments, this week: Urged retaining 30/25 MMT targets and not forcing offshore wind into the base case, citing cost and timing concerns.
- Imperial Irrigation District Reply comments, this week: Sought comparable modeling of commercially supported Imperial Valley geothermal, including its identified 172.5 MW of near-term projects and related transmission needs.
- EGX Energy Inc. Comments (stage unspecified), this week: Recommended modeling Pluth Ranch as 100 MW available in 2031 and another 300 MW by 2034, with associated transmission needs evaluated.
- Sonoma Clean Power Authority Reply comments, this week: Supported reconfiguring the California Gateway Connector Projects and retaining Hilltop access, citing regional geothermal and wind development interest.
- Maravillosa Solar Energy LLC,Invenergy Geothermal LLC Reply comments, this week: Urged greater in-state geothermal representation, including 2 GW in the IID area beginning in 2032, and a more balanced mix of out-of-state regions.
- Ormat Technologies, Inc Reply comments, this week: Supported retaining Hilltop and Control as geothermal delivery points, while considering Walker River as an additional—not replacement—pathway.
- Zanskar Geothermal & Minerals, Inc. Reply comments, this week: Urged recognizing Northern California geothermal interest and assessing direct Northern Nevada transmission alongside Hilltop and other delivery options.
- XGS Energy, Inc Reply comments, this week: Urged evidence-based, technology-specific geothermal timelines and project-viability measures beyond queue position to better represent clean-firm resources.
- California Wind Energy Association Reply comments, this week: Supported stronger Northern California transmission and recognizing in-state wind as long-lead, including energy-only projects with later deliverability upgrades.
- California Independent System Operator Corp. (Folsom, CA) Reply comments, this week: Supported 3,000 MW of Wyoming wind through TransWest Express in 2032 and consistent modeling of approved out-of-state transmission projects.
- Cal Advocates/M.Miley/CPUC Reply comments, this week: Recommended modeling the full 3 GW of Wyoming wind in 2033, reflecting TransWest Express’s revised configuration and upgrade timing.
- Bay Area Municipal Transmission Group Reply comments, this week: Recommended disclosure of out-of-state transmission scope, cost, timing and cost-allocation assumptions before embedding dependent resources in the base case.
- Golden State Clean Energy, LLC Opening comments, earlier: Supported disclosing out-of-state transmission assumptions and limiting generic interstate-line additions to reflect development timelines.
- Hexagon Energy, LLC Opening comments, earlier: Identified Northern California EGS development interest and urged mapping resources at Hilltop, Malin and Round Mountain with deliverability studies.
- Zanskar Geothermal & Minerals, Inc. Opening comments, earlier: Urged planning Northern California geothermal transmission alongside development, including evaluating Humboldt projects and a northern-corridor sensitivity.
- CALIFORNIA COMMUNITY CHOICE ASSOCIATION Reply comments, this week: Opposed a location-specific order before wires and non-wires alternatives, feasibility, cost and allocation questions are fully evaluated.
- CALIFORNIA ENERGY STORAGE ALLIANCE Reply comments, this week: Supported targeted storage procurement for the 2032 need, with a clear MW-and-MWh requirement, competitive solicitation and cost safeguards.
- Southern California Edison Company Reply comments, this week: Opposed ordering procurement on the present record, citing unresolved quantity, cost and feasibility; supported neutral competition for any solicitation.
- Pacific Gas and Electric Company Reply comments, this week: Found the record insufficient to establish need, timing or incremental procurement, and proposed a framework to compare procurement with transmission alternatives.
- California Independent System Operator Corp. (Folsom, CA) Reply comments, this week: Recommended 2,405 MW or 12,075 MWh of storage by 2032, citing the reliability gap before the Mesa transformer is available.
- Hydrostor, Inc. Reply comments, this week: Supported a durable Mesa–Mira Loma solution through storage or wires, noting deliverability effects extend beyond the constrained corridor.
- Solar Energy Industries Association,Large-scale Solar Association Reply comments, this week: Supported market-testing targeted storage procurement as a non-wires alternative to transmission upgrades in the Western LA Basin.
- GreenGenStorage, LLC Reply comments, this week: Sought project-specific pumped-storage costs and mapping for 400 MW at Bellota, with continued long-lead deliverability reservations.
- Mussey Grade Road Alliance Reply comments, this week: Recommended an updated cost assumption for 12-hour storage and opposed lowering pumped-storage outage rates without supporting data.
- Hydrostor, Inc. Reply comments, this week: Urged clear procurement signals for long-lead resources and proactive transmission evaluation, including upgrades at Lugo.
- Middle River Power LLC Reply comments, this week: Recommended modeling hybrid gas-and-battery facilities and carbon capture as candidate resources, while retaining gas capacity for reliability.
- California Resources Corporation Reply comments, this week: Requested a current-cycle CCS sensitivity and candidate-resource modeling in the next plan, with transparent assumptions and cost and capture-rate tests.
- Bay Area Municipal Transmission Group Opening comments, earlier: Supported retaining most gas capacity and prioritizing CCS modeling, while flagging uncertain costs and performance.
- Vote Solar Reply comments, this week: Urged greater DER and VPP integration and expanded energy-only resource use, including for battery charging and later deliverability upgrades.
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