14. Comments on Proposed Decision

On August 24, 2010, the proposed decision of Administrative Law Judge (ALJ) Burton W. Mattson in this matter was mailed to parties in accordance with Section 311 of the Public Utilities Code and Rule 14.3 of the Commission's Rules of Practice and Procedure (Rules). On September 27, 2010, comments were filed by Axio, CalSEIA, CARE, CEERT, DRA, enXco, FIT Coalition, Fuel Cell Energy, GPI, IEP, Jan Reid, LS Power Associates, PG&E, Recurrent Energy, SCE, SDG&E, SFUI, Sierra Club, Solar Alliance, Sustainable Conservation, TURN, and Vote Solar. On October 4, 2010, reply comments were filed on by CARE, DRA, FCE, FIT, GPI, Jan Reid, LS Power Associates, PG&E, SCE, SDG&E, SFUI, Solar Alliance, Sustainable Conservation, TURN, Vote Solar, Walmart, and Western Power Trading Group. The proposed decision was significantly modified to address the comments. Among other things: the value of RAM as a program to target viable renewable distributed generation that can interconnect quickly was clarified; the simplified preapproval threshold was eliminated; our intent to explore a more nuanced need for RAM by coordinating with the CPUC's procurement planning process was clarified; the discretion to reject bids that are not cost competitive or resulted in market manipulation was given to the IOUs; the requirements of some of contract terms and conditions were left to the discretion of the IOUs; the development deposit requirement was increased; the termination contract requirement was removed; the project size limit was changed to 20 MW; only the excess sales from a generator will count toward the 1,000 MW capacity limit; RAM documents need not be uniform across IOUs; the IOUs must provide more relevant preferred location information to bidders; the eligible location for RAM projects was limited to the IOU service territories; annual RAM reports shall be filed and the content determined in collaboration with Energy Division and IOUs; and a process is provided for timely modifications to the RAM program.