Joint IOU Petition for Modification of D.19-09-043 to Use of Effective Load Carrying Capacity Methodology from the IRP Proceeding in the RPS proceeding
PG&E, SCE, and SDG&E ("Joint IOUs") jointly filed a Petition for Modification ("Joint PFM") of D.19-09-043 to discontinue the annual determination of Effective Load Carrying Capacity (“ELCC”) values int the RPS proceeding, and instead request the ELCC values in the IRP proceeding be adopted for the ELCC of RPS resources. The IOUs argue that this modification will eliminate potential inconsistent results, redundancies, and increase efficiency in the RPS proceeding. The Joint IOUs seek to implement this modification in the RPS proceeding by Mid-2023. Responses are due November 14, 2022.
The following is a brief overview of the Joint PFM:
ELCC values are already calculated in the IRP proceeding through a robust and transparent process to consider and analyze inputs and assumptions and should not occur in the RPS proceeding. The Commission’s IRP Proceeding Provides an Updated, Centralized Study with Resource Reliability Metrics that Can and Should Be Used in the RPS Proceeding.
The D.19-09-043 ("Decision") directs the IOUs to calibrate the studied resource portfolio to reach a 0.1 loss of load expectation (“LOLE”) for marginal ELCC calculations and calculate marginal ELCC values using the most recently updated IRP portfolio as the resource baseline. The Decision's required calibration process is not used in other resource reliability studies and is not consistent with and reflective of system conditions and current best practices. These issues lead to the conclusion that the Commission’s specified calibration process can result in different outcomes that, in turn, would then send conflicting signals to the market and yield different policy outcomes.
Energy Division’s IRP Marginal ELCC Results of July 19, 2022, updated July 29, 2022, are not consistent with the 2022 Joint IOUs Marginal ELCC Results Primarily Due to Load Scaling Calibration Process prescribed in the Decision.
