Parties submit Comments on 2021 Draft RPS Plans

Comments were made by the Public Advocates Office ("Cal Advocates"), American Clean Power-California ("ACP-California"), Green Power Institute ("GPI"), and California Wind Energy Association ("CalWEA"). The City of Lancaster, City of Pico Rivera, City of San Jacinto, City of Rancho Mirage, Apple Valley Choice Energy, City of Baldwin Park, City of Pomona, City of Santa Barbara, Marin Clean Energy, Central Coast Community Energy, and Sonoma Clean Power Authority submitted comments as "Joint CCA Parties."

The following is a brief summary of some of the parties' comments and the link below provides parties' complete submissions.

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Joint CCA Parties' Comments:

• The Joint CCA Parties make two recommendations for procedural changes that would improve the Renewables Portfolio Standard (“RPS”) Procurement Plan process. These changes would provide necessary certainty regarding the status of final RPS Procurement Plans and would improve the initial instructions for the upcoming RPS Procurement Plan requirements.
• The Commission should provide retail sellers with formal notice that their Final RPS Procurement Plan has been accepted.
• The Commission should request party comments on new requirements for RPS Procurement Plans and the schedule in advance of issuing the ACR for that year’s RPS Procurement Plans.

Cal Advocates' Comments:

• The Commission should not grant SDG&E or SCE authority for an optional RPS procurement solicitation because they fail to demonstrate that RPS solicitations are required to meet forecasted compliance needs.
• SCE should not be authorized to hold an optional RPS procurement solicitation based on its Integrated Resources Plan procurement needs.
• SCE’s request for an optional RPS solicitation is based upon the uncertainty surrounding the VAMO and SCE’s use of an extreme forecasted outcome of the VAMO process. Because there is too much uncertainty surrounding the voluntary allocation methodology and the VAMO process, it is unreasonable for the Commission to provide SCE authority to hold optional RPS solicitations.
• To the extent that SCE is granted the authority to hold an optional RPS solicitation, the Commission should clarify that the solicitation is specific to needs arising from the VAMO. It should also require SCE to attest, in a Tier 2 advice letter, that the solicitation is necessary and that additional resources procured through the IRP do not satisfy any need arising from the VAMO.
• Moreover, the Commission should explicitly prohibit SCE from issuing an RPS solicitation to meet an IRP need. The IRP process has separate procurement mechanisms with specific reliability and other informational requirements that SCE must satisfy.
• The Commission should direct the IOUs to provide more information on the impact that selling excess RECs will have on their longer-term compliance obligations before approving any further REC sales.