R. 18-07-003
Pursuant to Ordering Paragraph ("OP") 2 of Decision (D.) 19-09-043, Pacific Gas and Electric ("PG&E"), San Diego Gas & Electric ("SDG&E"), and Southern California Edison ("SCE") (collectively, "Joint IOUs") submitted the 2022 Effective Load Carrying Capability ("ELCC") Study Report. The Joint IOUs do not support the use of the marginal ELCC values provided in this report to guide procurement decisions, and changes will be required to align future long-term reliability planning with a new resource adequacy ("RA") framework. Protests are due on July 21, 2022 and the Joint IOUS request Commission approval by July 31, 2022.
The Report includes the study methodology, assumptions, and marginal ELCC values for the following generating facilities:
- Fixed axis solar photovoltaic ("PV"),
- Tracking solar PV,
- Tracking solar PV paired with storage,
- Distributed solar PV,
- Wind, and
- Wind paired with storage.
The Joint IOUs have concerns about adopting the marginal ELCC values in the Final 2022 LECC Report because of the following methodology issues:
- The methodology constraints to calibrate the Strategic Energy and Risk Valuation Model ("SERVM") model to 0.1 loss of load expectation ("LOLE"), as ordered in D. 19-09-043, biases the Report results.
- The marginal ELCC values are likely not reflective of the reliability contributions of the Preferred System Plan ("PSP") resources, and are not useful for guiding procurement decisions intended to implement the PSP or for achieving any particular level of overall supply reliability.
- The approach of basing the report on the PSP resource portfolio, and the prescribed methodology, results in significantly inflated solar ELCCs and suppressed battery storage ELCCs.
- The Joint IOUs recommend that the ELCC values provided in the Report not be used to guide the procurement decisions and/or Commission Orders in the renewable portfolio standard ("RPS") proceeding or any other proceedings, such as resource adequacy ("RA") and integrated resource planning ("IRP").
- The Joint IOUs also recommend that the Commission make changes to the RPS and IRP proceedings to align with long-term reliability planning with the new slice-of-day framework adopted in D. 21-07-014.
