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Renewable Portfolio Standard ("RPS")
R. 18-07-003
April 4, 2022

IOUs Request Approval of Market Offer Pro Formas for the Sale of PCIA-eligble RPS Resources

PG&E, SCE, and SDG&E submit Advice Letters, pursuant to D. 22-01-004 Ordering Paragraph ("OP") 6 and D. 21-05-030, requesting approval of pro forma Market Offer Sales Agreements ("Market Offer Agreements"). The Market Offer Agreements implement the sale of all PCIA-eligible RPS energy remaining after the VAMO process. Protests and comments are due April 25, 2022.

Background:

The Market Offer process must have the following elements, pursuant to D. 21-05-030:

  • The Market Offer shall offer for sale all PCIA-eligible RPS energy remaining after a Voluntary Allocation.
  • The Market Offer process shall be based upon existing processes, rules, oversight requirements, and reporting requirements for REC solicitations previously approved in the Commission’s RPS proceeding.
  • The Market Offer process should include rules for utility participation in solicitations they administer.

Review of the Market Offer process will be reviewed in the IOUs' Draft 2022 RPS Procurement Plans unless the March 10, 2022 Joint IOU Motion seeking submittal of the Market Offer process and schedule through a Tier 3 Advice Letter is approved by the Commission.

The Market Offer Agreements must meet the following requirements, pursuant to D. 21-05-030, OP 3:

  • The Market Offer process will offer all PCIA-eligible RPS energy remaining after each Voluntary Allocation process.
  • The Market Offer Contracts are based upon existing Portfolio Content Category ("PCC") 1 and 3 REC Sales Agreements previously approved in the Commission’s RPS proceeding.

Market Offer Contracts:

PG&E AL 6551-E:

PG&E’s Market Offer Contract is a confirmation to PG&E’s Edison Electric Institute (“EEI”) Master Power Purchase and Sale Agreement (“Master Agreement”), similar to the existing confirmation used in PG&E’s bundled RPS energy sales. Participants in the Market Offer process will need to have a Master Agreement in place with PG&E prior to the execution of the Market Offer Contract. The primary differences between PG&E’s CPUC-approved bundled RPS energy sale contract (“RPS Sale Contract”) and the proposed Market Offer contract are related to the products offered and their respective delivery periods. Notably, Appendices B and C provide a list of resources in both short-term and long-term pools.

SCE AL 4759-E:

SCE developed two Market Offer Pro Forma Contracts - one for bundled REC sales and one for unbundled REC sales ("Market Offer Contracts"). The Market Offer Contracts include many concepts familiar to parties from SCE’s Commission-approved PCC 1 and 3 REC Sales Agreements (collectively, the "REC Sales Agreements"), including terms and conditions from the Edison Electric Institute Master Power Purchase and Sale Agreement modified with SCE’s standard terms and provisions ("EEI Enabling Agreement"). The PCC 3 REC Sales Agreement does not rely on the use of an EEI Enabling Agreement. SCE intends for its Market Offer Contracts to be nonnegotiable, standard offer contracts to facilitate the contracting process. SCE is also seeking to submit a related Tier 3 advice letter proposing its Market Offer Process on April 29, 2022.

SDG&E AL 3983-E:

SDG&E developed two Market Offer Pro Forma Contracts - one for bundled REC sales and one for unbundled REC sales ("Market Offer Contracts"). The Market Offer Contracts modify SDG&E’s Commission-approved Bundled and Unbundled REC Sales Agreements. For the sale of bundled and unbundled RECs, SDG&E modified Article(s) 1, 2, and 7. The most notable change being the use of arbitration for dispute resolutions and additional project facility information.

Update Links
SEE PROCEEDING
RELATED UPDATES
R. 17-06-026

Joint IOU Implementation of RPS VAMO

SEE UPDATE
R. 18-07-003

IOUs Request that the Market Offer Process Timely Start After Voluntary Allocations

SEE UPDATE

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