Cogeneration Association of California (CAC) and Energy Producers and Users Coalition (EPUC)

CAC/EPUC centered its attention on large¹³ CHP units and recommends that the Commission require SCE and PG&E to procure from new CHP facilities, now, to meet their baseload needs. CAC/EPUC promotes (1) the reliability of new large CHP facilities and; (2) the possibility that they could also provide energy savings and reduce CO2 emissions. CAC/EPUC argues that if the IOUs do not signal their move in the direction of procuring from new, reliable CHP facilities to fill their resource needs, the opportunity may be lost if investors do not choose to install new CHP facilities. CAC/EPUC suggests that the IOUs be directed to meet their need from CHP resources before procuring power from fossil-fueled resources.

CAC/EPUC also touts the benefits of Customer Generated Departing Load (CGDL)¹⁴ as increasing grid reliability through facility-level reliability, collective contributions to system reliability and reduced reliance on imports. In addition, CAC/EPUC argues that the EAP II loading order recognizes the benefits of CHP, but the IOUs have not encouraged CHP as a procurement option. CAC/EPUC asks the Commission to direct the IOUs to assume that 100% of CHP QFs recontract and that new baseload need will be met by new CHP QF power.

¹³ CAC/EPUC defines large as a CHP facility with a nameplate capacity greater than 20 MW.

¹⁴ CAC/EPUC defines customer generation as including cogeneration, renewable technologies such as solar panels, fuel cells or any other type of generation that is constructed with private investment capital and is dedicated wholly or in part to serving onsite customer load. (CAC/EPUC Opening Brief, p. 11.)