California Clean DG Coalition (CCDC)

CCDC promotes the ability of DG system manufacturers, distributors, marketers and investors, and electric customers, to deploy DG. Members of CCDC represent a variety of DG technologies including CHP, renewables, gas turbines, microturbines, reciprocating engines and storage.¹⁷ CCDC's concerns in this proceeding were on the IOUs' forecasts, need determination and nonbypassable charges. In its brief, CCDC acknowledges that nonbypassable charges is the subject of Phase 3 of this proceeding, but it comments that forecast and need issues are inextricably tied to nonbypassable charges. Therefore, CCDC asks the Commission to direct the IOUs to reflect reasonable and realistic DG estimates in their load forecasts so that the IOUs do not procure power or system reliability resources for and incur costs on behalf of CHP DG identified in their forecasts. Without arguing nonbypassable charges, CCDC focuses on accurate and consistent DG forecasts.

To begin, CCDC argues that the IOU CHP DG forecasts are "wholly at odds with the recent CEC-sponsored CHP assessment cited in the 2005 IEPR."¹⁸ CCDC urges the Commission to require the IOUs to revise their CHP DG forecasts to be consistent with the CEC assessment and the 2005 IEPR. Instead of using the CEC's numbers, CCDC argues that the IOUs use the historic DG rates. Without arguing the issue of nonbypassable charges, CCDC claims that the IOUs are at risk of overprocuring resources because of their undersassumptions about DG departing load. CCDCasks the Commission to direct the IOUs to not procure for CHP DG identified in their LTPP forecasts.

¹⁷ CCDC Opening Brief, p. 1, lists all current members, Footnote 1.

¹⁸ CCDC Opening Brief, p. 3.