Draft Resolution E-5216 Approves IOUs Pro Forma RPS VAMO Contract Language

Modifications to Proposed Contracts:

• San Diego Gas & Electric ("SDG&E") shall modify its Voluntary Allocation pro forma contract to permit load serving entities ("LSE") to elect allocations of PCIA-eligible RPS resources from both the short-term and long-term allocation resource polls as a short-term allocation.
• SDG&E shall modify its Voluntary Allocation pro forma contract to clarify that utility-owned generation ("UOG") and evergreen resources are eligible resources for Voluntary Action
• SDG&E shall modify its Voluntary Allocation pro forma contract to include the following language for changes to its allocation resource pools: Within fifteen (15) day's prior notice to Buyer, Seller may add or remove a Resource from the Resource Pools for the following reasons: (i) if Seller's power purchase agreement corresponding to the Resource has been modified, terminated, or assigned to a third party, (ii) if the Resource is no longer in Seller's PCIA-eligible portfolio due to Commission order or direction, or (iii) if the Resource is owner by Seller but ceases operation for Seller.

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The Commission Accepted:

• CalCCA's protest for IOUs to permit LSEs to take both short-term RPS resources and long-term REPS resources as a short-term allocation
• CalCCA's protest and SCE's supplemental Advice Letters that utility-owned generation (and evergreen contracts) should be included in long-term voluntary actions, provided they otherwise meet applicable conditions for being included in those allocations
• CalCCA's protest for SDG&E to adopt the following language in its pro forma: Within fifteen (15) day's prior notice to Buyer, Seller may add or remove a Resource from the Resource Pools for the following reasons: (i) if Seller's power purchase agreement corresponding to the Resource has been modified, terminated, or assigned to a third party, (ii) if the Resource is no longer in Seller's PCIA-eligible portfolio due to Commission order or direction, or (iii) if the Resource is owner by Seller but ceases operation for Seller.

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The Commission Denied:

• AReM's protest to extend the timeline for the execution of Voluntary Allocation contracts
• AReM's protest to direct SDG&E to modify its Voluntary Action pro forma contract to include the specific length of short-term allocations
• AReM and CalCCA's protest to determine the PCC classification of RECs subject to this Resolution and to order the IOUs to include in their Voluntary Allocation pro forma contracts the PCC classification of allocated RECs
• CalCCA's protest to direct the IOUS to provide LSEs with forecast and meter data within fifteen calendar days of the end of a Voluntary Allocation contract's "Calculation Period"
• CalCCA's protest to SDG&E's collateral requirements
• CalCCA's protest to SDG&E's arbitration requirement
• CalCCA's protest to SDG&E's definition of losses
• The San Diego CCAs' objection to SDG&E pricing its bundled and unbundled pro forma contracts at the RPS MPB