8. Renewable Integration Products

SCE requests Commission approval to add "Renewable Integration Products" to the list of approved procurement products. (Ex. 202 at 65-66; SCE Opening Brief at 18.) SCE's description of these Renewable Integration Products is very general, and notes that they could consist of either financial or physical transactions. (Ex. 202 at 66.) SCE does not provide a clear definition of Renewable Integration Products, but rather provides examples of what the products "may be" or "could include." (SCE Opening Brief at 18.)

PG&E supports SCE's request, and provides a definition of Renewable Integration Products as: "Structured, physical or financial, products to allocate the risk associated with the variable output of intermittent resources. Products include, but are not limited to, those offered directly from a Balancing Authority." (Ex. 103 at II-7-II-9.)

Pacific Environment opposes this request, arguing that "it is unclear exactly what types of physical resources and financial arrangements SCE and PG&E are asking the Commission to approve..." (Pacific Environment, Opening Brief at 28.) According to Pacific Environment, SCE's and PG&E's definitions of Renewable Integration Products are neither clear nor informative, and accordingly do not meet the requirements of AB 57. (Id.) CBE takes a similar position, arguing that SCE has not adequately explained what the Commission would be approving. (CBE Reply Brief at 6.)

DRA appears to be of several minds on this issue. DRA states that in its opening testimony it did not object to the use of renewable integration products, but opposed SCE's request to add them to the list of approved procurement products, on the grounds that it was not clear which renewable generation contracts they would apply to, there was no list or definition of what products would fit into the category, there was no calculation or estimate of the costs, there was no description of how the products related to the California Independent System Operator's (CAISO) 33% renewable integration study, and it was unclear exactly what authority SCE was actually seeking. (DRA Opening Brief at 20.)

DRA goes on to state that, based on additional information it obtained from SCE in subsequent conversations with SCE staff and in responses to data requests, DRA no longer objects to SCE's request. (Id.) But in its Reply Brief, DRA agrees with Pacific Environment that SCE and PG&E have not provided sufficient detail to clearly identify what Renewable Integration Products actually consist of, and asks the Commission to direct SCE and PG&E to provide more detail. (DRA Reply Brief at 6-7.)

We agree with Pacific Environment, CBE and DRA. While there will certainly be a need for renewable integration, and there may or may not be anything wrong with the products that SCE and PG&E might seek to procure for that purpose, the request of SCE and PG&E is simply too vague and broad for the Commission to know what it would actually be approving. Accordingly, we decline to add "Renewable Integration Products" to the list of approved procurement products at this time.