Proposed Decision Orders Modifications for Draft 2021 RPS Procurement Plans
The Commission 's Proposed Decision ("PD") orders modifications to the IOUs and many of the CCA's Draft 2021 RPS Procurement Plans. Final 2021 RPS Procurement Plans will be due no later than 30 days following the Commission's approval and issuance of this Proposed Decision.
The following is an overview of the Commission's comments in the PD:
Summary (CCAs & ESPs):
28 CCAs and 10 ESPs filed Draft 2021 RPS Plans. The significant issues to consider in the Final RPS Plans are participation in the Voluntary Allocation Market Offer (VAMO) process, mid-term reliability, and the RPS planning process to meet the 65 percent long-term contracting requirements.
Most of the CCAs and ESPs did not provide information on whether and to what extent they would participate in the Power Charge Indifference Adjustment (PCIA) VAMO process. The Final 2021 RPS Plans shall provide supporting information on the four portfolio optimization strategies on a retail seller’s VAMO participation.
Last year we projected that CCAs need additional RPS procurement starting in 2021. Together, the CCAs executed enough renewable energy contracts to exceed their forecasted need in 2021 as they plan to serve 60,000 GWh of retail load in 2022. With an increased footprint, about 50 percent of the CCAs already meet the 65 percent long-term contract requirement for the current compliance period (2021-2024).
We expect the CCAs and ESPs to provide a well-supported analysis while considering the impact of the mid-term reliability Decision 21-06-035 on their portfolio optimization and risk assessment to support their procurement strategies and compliance needs.
CCA and ESP Requests:
The Joint CCAs request that the Commission somehow provide retail sellers formal notice that their Final RPS Procurement Plan has been accepted, such as via a letter from the Director of Energy Division served on the service list for R.18-07-003 (or its successor).
For a retail seller is directed by the Commission to submit a final RPS Plan, Energy Division should set a process whereby they are able to inform a retail seller that its Final RPS Plan met the expectations of the Commission.
The Joint CCAs recommend that the Commission seek input from the parties, early in the process, on both the new requirements for that year’s RPS Procurement Plans as well as the overall schedule. We decline to adopt this recommendation in this decision.
Appendix A - Required Updates in Final 2021 RPS Plans:
