PG&E and seven CCAs submitted Tier-2 Advice Letter requests for a waiver of penalties and obligations associated with their 2022 local RA requirements. The requests largely came from LSEs in the PG&E service area, with SDCP being the only exception. The LSEs generally cite increased local capacity area requirements and market constraints as the primary factors underlying their respective deficiencies. SDCP’s waiver request also raises market power concerns and further points out that procurement efforts were impacted by regulatory uncertainty due to the stalled development of the modified CAM.
The following LSES distributed waiver requests to the R. 19-11-009 service list on November 1, 2021:
• PG&E
• Silicon Valley Clean Energy Authority
• San Jose Clean Energy Authority
• CleanPower SF
• Redwood Coast Energy Authority
• East Bay Community Energy
• Sonoma Clean Power Authority
• San Diego Community Power
SDCP’s Local RA Waiver Request indicated that, despite good faith efforts, it was unable to find sufficient local RA capacity to meet its obligations. SDCP pointed out difficulty engaging with SDG&E, and PG&E’s reluctance to sell certain local resources until after the modified CAM is developed.
Beginning in 2021, LSEs in the PG&E service area are permitted to fulfill Local RA procurement obligations if the following obligations are met:
(a) The LSE makes the required demonstration as part of the current local
waiver process through a Tier 2 Advice Letter for its disaggregated
PG&E Other local capacity requirements; and
(b) The LSE, in its Year Ahead compliance filing, demonstrates
procurement of local RA capacity within the PG&E Other LCAs such
that the LSE’s collective procurement in the six disaggregated PG&E
Other LCAs meets the LSE’s collective requirement for the
disaggregated PG&E Other LCAs.
Accordingly, several LSEs included requests for a waiver of obligations in addition to their request for a waiver of penalties
