Comments on Track 3B.1 and Track 4

CalCCA:

• Move toward a marginal ELCC for solar/wind resources at more measured pace than Staff’s proposed reduction of solar ELCC to zero.
• Staff should refine its MCC buckets proposal to include clear rules to recognize the value of long-duration storage and hybrid resources.
• Supports AReM’s proposed partial penalty rebate for LSEs that cure their deficiencies within the prescribed time.
• Agrees with Joint Parties - enable DERs to provide RA capacity.
• Be cautious in requiring higher PRM in current market conditions