CalCCA Protests IOUs' Advice Letters Seeking Approval of Market Offer Pro Formas

PG&E AL 6551-E

The Commission should not approve the market offer pro forma contract (Market Offer Contract) unless it is revised as follows:

• Bidders must be allowed to bid on bundled resource pools independent of any bid on unbundled resource pools, as is allowed under Southern California Edison’s (SCE’s) and San Diego Gas & Electric Company’s (SDG&E’s) market offer pro forma contracts; and
• Counterparties to the Market Offer Contract should be provided timely access to meter data, which is necessary for operational and planning purposes.
• CalCCA reserves the right to comment on the terms of the Market Offer Contract following the filing of the investor-owned utilities’ (IOUs’) “Market Offer Process” and sales strategy documents in May.

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SCE AL 4759-E

• SCE should be required to provide timely access to meter data, which is necessary for load-serving entity (LSE) operational and planning purposes.
• CalCCA reserves the right to comment on the terms of the market offer pro formas (Market Offer Contracts) following the filing of the investor-owned utilities’ (IOUs’) “Market Offer Process” and sales strategy documents in May.

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SDG&E AL 3983-E

• The Commission should not approve the market offer pro forma contracts (Market Offer Contracts) until potential counterparties receive more information regarding the products, composition of the resource pools available, and other terms and conditions of the market offer that will have a material impact on the value of the resources to be offered. The Market Offer Contracts cannot be adequately reviewed at this time, with many fundamental issues regarding the structure of the market offer and the resources to be made available still unknown.
• The Commission should extend the protest period for the Market Offer Contracts through the comment period for the investor-owned utilities’ (IOUs’) market offer process and subsequent confidential sales strategy submission, which comment period is currently scheduled to end in early June 2022.
• SDG&E’s Market Offer Contracts should not be approved unless counterparties to the Market Offer Contracts are provided timely access to meter data, which is necessary for load-serving entity (LSE) operational and planning purposes.