The PD adopts local capacity requirements for 2022-2024, flexible capacity requirements for 2022, and additional refinements to the RA program including a tiered structure System RA penalty structure and changes to the RA import rules. In its Opening Comments on the PD, CalCCA opposed the additional System RA penalty structure and proposed that the Commission adopt a waiver process instead. CalCCA also opposed the new RA Import review process and stated that it would create additional uncertainty for LSEs.
The PD:
CalCCA's Opening Comments focused on the System RA penalty structure and RA Import rules. Specifically, CalCCA recommends:
As CalCCA highlighted in its comments on the RA Track 2 Proposed Decision, the Commission adopted the local RA waiver on two grounds: to address significantly increased costs or the exercise of market power, and to prevent making LSEs that are unable to contract for sufficient local RA to meet their requirement “subject to both backstop procurement costs and potential penalties.” Both factors also apply to system RA today. It is worth noting that both Western Community Energy (WCE) and San Diego Community Power (SDCP) filed and received waivers for their respective 2021 local RA showings. . . However, at the same time under the same circumstances, the Commission cited the LSEs for system RA deficiencies for the same RA year they received their local waiver. . .
