Parties Filed Opening and Reply Comments on the Proposed Decision Modifying the ReMAT Program

The following is a brief snapshot of parties opening comments:

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CalCCA:

• The Commission should recognize that unbundled customers do not currently benefit equally from the Renewable Market Adjusting Tariff ("ReMAT") contracts, given that bundled customers retain the Renewable Portfolio Standard ("RPS") and Resource Adequacy ("RA") benefits from the contracts.
• The Commission should find the current Power Charge Indifference Adjustment ("PCIA") cost recovery methodology appropriate given the PCIA was designed to address above-market costs of utility-procured resources, including RPS resources.
• The Commission must consider the differences in public policy goals of the Biofuel Market Adjusting Tariff ("BioMAT") and ReMAT programs prior to scoping or deciding on the ReMAT program’s cost allocation.
• If the Commission grants the Investor-Owned Utilities’ ("IOUs’") request for Public Policy Program Charge ("PPPC") recovery of ReMAT costs, it should clarify that the PPPC will recover all ReMAT costs and not just above-market costs and allow all customers (including unbundled customers) to receive the ReMAT products and attributes (RPS credits and RA) on a long-term basis.

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SDG&E:

• The Commission should not require SDG&E to reopen its Commission-approved closure of ReMAT and should revise the text of the PD to align with SDG&E’s compliance with the Commission’s program closure rules.
• If the Commission mandates additional ReMAT procurement from SDG&E, the Commission should make the following additional modifications to the PD: (1) The Commission should delay implementation of SDG&E’s ReMAT program; (2) Because reopening ReMAT will unfairly shift costs to SDG&E’s bundled customers, the Commission must allow IOUs the option to track costs in a memorandum account; (3) ReMAT procurement should count toward IRP procurement mandates to help manage costs and to facilitate alignment between RPS and IRP resource planning; (4) Daisy chaining: tariff changes to prevent gaming.