Calpine Corporation (Calpine)

Calpine's primary point of concentration in this proceeding is on the procurement process and the Commission's role in developing fair, open and transparent competitive solicitations that provide for head-to-head comparison of resource options. Calpine urges the Commission to ensure such a solicitation process by (1) prohibiting the IOUs from excluding existing generation resources from participating in RFOs; (2) limiting cost-of-service bids to costs and operating performance standards contained in the bid package; (3) promoting all-source RFOs that allow head-to-head competition between UOG and PPAs; (4) disallowing the use of DE by the IOUs when comparing PPAs; and (5) not allowing a preference for AB 1576 repowering projects. Calpine argues that the adoption of these recommendations will promote competitive solicitations that result in the procurement of the least cost/best fit resources.