R. 21-10-002
CalCCA filed a Petition for Modification ("PfM") of D. 22-03-034 to modify the Resource Adequacy ("RA") timeline and adopt an interim system RA waiver process. The Commission issued a Proposed Decision rejecting CalCCA's PfM, indicating that the Commission already addressed the PfM's concerns by not sending deficiency notices to LSEs for year-ahead RA obligations until After January 1, 2023. CalCCA opposes the PD and urges the Commission to adopt its recommendations made in the PfM.
D. 22-03-034 was meant to correct the Central Procurement Entity's ("CPE") deficiency in the two-year ahead showing. However, the shortfall was not resolved as anticipated for the year-ahead showing in September 2022. CalCCA argues that the Commission should reconsider the new circumstances and how they have interfered with LSE's ability to plan their RA procurement.
Further, CalCCA argues that the Commission did not consider the extreme nature of market scarcity when it issued D. 22-03-034.
CalCCA issues the following recommendations:
- Immediately “suspend” a portion of a load-serving entity’s (LSE’s) annual system and flexible RA compliance requirements until after the California Independent System Operator Corporation (CAISO) has performed local resource adequacy (RA) backstop for the Central Procurement Entity (CPE);
- Immediately “suspend” a portion of an LSE’s January - March monthly system and flexible RA compliance requirements until after the CAISO has performed local RA backstop for the CPE;
- Assess deficiency penalties for the unsuspended portion of the annual system RA requirement no earlier than January 1, 2023, as Decision 22-03-034 currently provides;
- Once the CAISO has completed its backstop, but not later than January 15, 2023, update annual system and flexible RA requirements for the remainder of the year, accounting for system and flexible allocations resulting from backstop;
- Require LSEs then to meet the “suspended” portion of their annual and monthly system RA, as adjusted, not later than May 1, 2023; and
- Further recognizing that the uncertainty and complexity added by the CPE may leave LSEs unable, despite reasonable efforts, to procure their system and flexible RA requirements, the Commission should adopt – for all investor-owned utility service areas – an interim process for an LSE to seek a waiver of system and flexible RA penalties under these circumstances.
