V. Comments on Draft Decision
The draft decision of ALJ Simon in this matter was mailed to the parties in accordance with Pub. Util. Code § 311(g)(1) and Rule 77.7 of the Rules of Practice and Procedure. Comments were filed on ____________.
1. It is reasonable for utilities to make estimates of future procurement from specific types of renewable resources for planning purposes.
2. It is reasonable for utilities to plan for the possibility that not all planned renewable developments will deliver the planned-for energy, whether due to erosion of the baseline renewable resources, errors in load forecasting, transmission constraints, or unforeseen difficulties in project development.
3. It is reasonable for utilities to make estimates of future needs for transmission, delivery points, remarketing costs, and other delivery issues for renewable resources for planning purposes.
4. The planning estimates of the utilities for the year 2010 currently identify wind, geothermal, and solar thermal resources as significant sources of renewable energy procurement; these resources may be located in areas that are remote from the utility's load center.
5. The plans do not adequately address the consequences of the estimated reliance on resources that may be remote from the utilities' load center.
6. The long-term RPS plans of the utilities do not address all areas necessary for adequate RPS planning.
7. It is reasonable to require the utilities to supplement their plans, as needed, with respect to transmission planning, repowered wind resources, and alternative and contingency planning.
1. Utilities should provide analysis and reasoned discussion in their RPS planning of the consequences of reliance for RPS procurement on resources remote from their load centers.
2. Utilities should address in their long-term RPS planning the availability of renewable resources and transmission planning (including delivery outside the utility's service territory, curtailablity, remarketing costs and benefits, and other alternatives to building new transmission).
3. Utilities should address in their long-term RPS planning the repowering of wind facilities currently under contract to the utility.
4. Utilities should include in their long-term RPS planning analysis that includes high, low, and base case scenarios.
5. Utilities should address in their long-term RPS planning potentially significant impediments to RPS compliance and include contingency planning addressing the identified impediments.
6. Utilities should explicitly address in their long-term RPS planning lessons learned from previous planning cycles.
7. In order to guard against shortfalls of planned renewable energy deliveries, utilities should provide in their RPS planning for procurement greater than the annual IPT required to reach the goal that 20% of their retail sales of energy be from eligible renewable resources by 2010.
8. Beginning in 2006, utilities' long-term planning for RPS compliance should be integrated with their general long-term procurement planning, in R.04-04-003 or its successor proceedings.
9. In integrating RPS planning with general procurement planning, utilities should specifically identify RPS planning components.
10. In order to begin more complete RPS planning, the utilities should, within 30 days of the mail date of this decision, supplement their current filings as follows:
a. PG&E must include:
(1) Basic analysis of the likelihood of development of its preferred renewable resources by 2010;
(2) Basic analysis of possible needs for transmission upgrades by 2010;
(3) A conceptual plan, including a timeline, for pursuing repowering opportunities for wind resources in the Altamont Pass Wind Resource Area;
(4) Contingency planning that addresses the most significant potential impediments to compliance with the 20% by 2010 goal.
b. SCE must include:
(1) Analysis of possible needs for transmission upgrades, with reference to those that are most needed for compliance with the 20% by 2010 goal;
(2) Contingency planning that addresses the most significant potential impediments to compliance with the 20% by 2010 goal.
c. SDG&E must include:
(1) Analysis and discussion, including a timeline, of possible transmission upgrades to be operating by 2010;
(2) Analysis of the impact of delivery points outside its service territory, bids having curtailability as an attribute, and remarketing arrangements on its ability to attain the 20% by 2010 goal;
(3) Contingency planning that addresses the most significant potential impediments to compliance with the 20% by 2010 goal, including transmission constraints and the absence of a market mechanism for using tradable RECs for RPS compliance.
11. In order for RPS planning to move forward expeditiously, this decision should be effective today.
IT IS ORDERED that:
1. Not later than 30 days from the mailing date of this decision, Pacific Gas & Electric Company (PG&E) must serve and file a supplement to its long-term procurement plan for the Renewables Portfolio Standard (RPS) program, including at least the following elements:
(a) Basic analysis of the likelihood of development of its preferred renewable resources by 2010;
(b) Basic analysis of possible needs for transmission upgrades by 2010;
(c) A conceptual plan, including a timeline, for pursuing repowering opportunities for wind resources in the Altamont Pass Wind Resource Area;
(d) Contingency planning that addresses the most significant potential impediments to compliance with the RPS goal of 20% of retail sales generated by eligible renewable resources by 2010.
2. Not later than 30 days from the mailing date of this decision, Southern California Edison Company (SCE) must serve and file a supplement to its long-term RPS procurement, including at least the following elements:
(a) Analysis of possible needs for transmission upgrades, with reference to those that are most needed for compliance with the 20% by 2010 goal;
(b) Contingency planning that addresses the most significant potential impediments to compliance with the RPS goal of 20% of retail sales generated by eligible renewable resources by 2010.
3. Not later than 30 days from the mailing date of this decision, San Diego Gas & Electric Company (SDG&E) must serve and file a supplement to its long-term RPS procurement, including at least the following elements:
(a) Analysis and discussion, including a timeline, of possible transmission upgrades to be operating by 2010;
(b) Analysis of the impact of delivery points outside its service territory, bids having curtailability as an attribute, and remarketing arrangements on its ability to attain the 20% by 2010 goal;
(c) Contingency planning that addresses the most significant potential impediments to compliance with the RPS goal of 20% of retail sales generated by eligible renewable resources by 2010, including at least transmission constraints and the absence of a market mechanism for using tradable RECs for RPS compliance.
4. The utilities' future long-term plans for RPS compliance shall be conducted as part of general procurement planning in Rulemaking 04-04-003 or its successor proceedings.
5. The utilities' future long-term plans for RPS compliance shall include specific and identifiable RPS planning components in general procurement planning documents, and shall address at least the following topics:
· available renewable resources;
· transmission planning (including planning for delivery points outside the utility's service area, for curtailability of delivery, remarketing, and other alternatives to construction of new transmission upgrades);
· high, low, and base case scenarios, with analytic support for each;
· repowering of wind facilities currently under contract to the utility;
· any need to guard against shortfalls of planned deliveries by procurement greater than the annual incremental procurement target required to reach the goal that 20% of their retail sales of energy be from eligible renewable resources by 2010; and
· identification of potential significant impediments to RPS compliance; and contingency planning addressing the identified impediments.
This order is effective today.
Dated , at San Francisco, California.
