III. Comments on Draft Decision

The draft decision of the assigned ALJ was mailed to the parties in this proceeding in accordance with Section 311(g)(1) and Rule 77.7 of the Rules of Practice and Procedure. Comments and/or reply comments were filed by PG&E, CalWEA, SDG&E, CEERT, and TURN. Two issues were raised in comments that merit attention here.

CalWEA notes that the word "should" has changed to "may" in the draft decision's discussion of how the utility will consider possible network benefits. While we recognize that the Commission has not yet developed a methodology for considering network benefits, we do not want to eliminate the possibility that such benefits could be made evident in the course of evaluating particular RPS bids. We do not want to miss clear-cut opportunities to benefit the network via the addition of particular renewable energy resources. Accordingly, we direct the utilities to develop consistent, logical approaches to assessing these potential benefits, to the level of detail that is feasible over the course of this year's RPS solicitation. This evaluation process should be transparent to the utility's Procurement Review Group and to the Commission. We modify the language in the draft decision and Appendix to reflect this change.

7 This direction was encapsulated in Finding of Fact 34 and Ordering Paragraph 18 of D.03-06-071.

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