14. Short-Term Renewable Contracts

SCE requests Commission authorization to enter into short-term renewable energy transactions, for either bundled generation or stand-alone renewable energy credits (RECs). (SCE Opening Brief at 15-17.) SCE proposes a methodology under which the Commission would pre-approve SCE entering into renewable contracts lasting up to five years to purchase "up to a predetermined amount" of renewable generation or RECs. (Ex. 202 at 52-53.)¹²

CEERT strongly supports SCE's request. (CEERT Opening Brief at 1-11.) DRA opposes this proposal. (DRA Opening Brief at 21-23.) TURN also opposes it, arguing that SCE is asking for authority to procure up to 3750 gigawatt hours of energy that may in fact not be eligible for RPS compliance. (TURN Opening Brief at 5-8.)

This issue is more appropriately addressed in the Commission's RPS proceeding (R.11-05-005), where the Commission is comprehensively examining issues relating to the implementation of the recently amended RPS statute, including contracting issues. Accordingly, we do not consider the merits of SCE's proposal here. SCE's proposal to enter into pre-approved short-term renewable energy transactions is not approved, but SCE may request that (or similar) authority in the RPS proceeding.

¹² This amount is not clearly identified in SCE's testimony or briefs.