The Joint Parties filed a motion94 on December 19, 2011 and noted their concern that the Commission or ALJ had given the Renewable FiT Staff Proposal greater consideration or more evidentiary weight than other pricing proposals because the Staff's Proposal was presented in an ALJ's ruling dated October 13, 2011 and, in addition, was discussed at a Staff Workshop on September 26, 2011. These concerns were presented in a motion seeking further consideration in a workshop on the record of an "administratively determined, avoided-cost based pricing mechanism."95 The motion stated that further consideration of such a pricing mechanism was needed because the ALJ's October 13, 2011 ruling, in combination with the Renewable FiT Staff Proposal, effectively demonstrated to the Joint Parties that the Staff Proposal would, in some form, prevail before the Commission.
We emphasize that the Renewable FiT Staff Proposal was one of many pricing proposals considered by the Commission in this proceeding. The Joint Parties' suggestion that the record was unduly limited by the Commission's consideration of the Renewable FiT Staff Proposal is misplaced. The Commission gave full consideration to all pricing options presented in the proceeding, including that of an "administratively determined, avoided-cost based pricing mechanism."
Moreover, we emphasize that all parties had ample opportunities to present their pricing proposal to the Commission. Pricing proposals were requested in early and late March 2011 and, again, in July and August 2011. In November 2011, we sought input on pricing issues from parties. While the November 2011 comments focused on the Renewable FiT Staff Proposal, we sought input on a broad basis seeking to understand the pros and cons of the Staff Proposal as compared to various alternative-pricing proposals.
The motion is denied.
94 Joint Motion of the Center for Energy Efficiency and Renewable Technologies; AG Power Group, LLC; Sustainable Conservation; Agricultural Energy Consumers Association; Green Power Institute; California Wastewater Climate Change Group; California Farm Bureau Federation; Fuel Cell Energy; and FlexEnergy, Inc., for a Ruling Directing the Consideration of an Administratively determined Avoided Cost Pricing Methodology for the Renewable FIT at a January 2012 Workshop that Would be Part of the Record for the Decision on the Renewable FIT filed December 19, 2011.
95 Id. at 5.