Opening Comments on ALJ Ruling Questions re: ReMAT Program

The following is a brief snapshot of comments:

CalCCA

• Allow retail providers access to the ReMAT program since their customers also pay its costs.
• Fair cost and benefit allocation must be ensured to prevent cost shifting.

Joint IOUs

• CPUC should maintain the current allocations and not reassign as-available non-peaking or baseload categories allocations to the as-available peaking category.
• Non-IOU retail sellers are not eligible to participate in ReMAT as buyers under the current statutory framework.
• SDG&E requests that the ReMAT closure rules remain unchanged and is against any expansion or extension of the ReMAT program.

Cal Advocates

• The Commission should not modify the ReMAT program at this time.
• The Commission cannot allow Non-Investor-Owned Utility (IOU) Load Serving Entities (LSEs) to participate in the ReMAT program due to statutory limitations.
• The Commission should not require the IOUs to pay resources differently based on time-of-delivery (TOD).
• The Commission should not allow eligible renewable energy resources paired with energy storage to be eligible under ReMAT at this time.