California CCAs, including San Diego Community Power, Receive Proposed Decision for 2019 RPS Plan

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Stoel Rives - Renewable + Law

On August 19, the California Public Utilities Commission (CPUC) issued a proposed decision accepting the 2019 Renewables Portfolio Standard Procurement Plans submitted by four new Community Choice Aggregators (CCAs): Butte Choice Energy Authority; Clean Energy Alliance; the City of Santa Barbara; and San Diego Community Power.  Each of these CCAs is anticipated to start providing electricity to customers in 2021.  As we have noted previously, San Diego’s CCA is forecasted to serve a total load of over 6,000 GWhs, making it one of the largest CCAs in California.

While the CPUC accepted, and deemed as final, the RPS Plans for these CCAs, the CPUC cautioned that going forward the CCAs must submit more detailed RPS Plans and improve the quality of their filings.  San Diego Community Power’s RPS Plan deficiencies recognized by the CPUC included (i) a more robust assessment of risk was needed, (ii) clarification of whether San Diego anticipated being able to use its excess renewable resources to meet its Minimum Margin of Procurement (MMoP), (iii) more detailed information on the bid solicitation protocol when procurement activities commence, (iv) how it will address curtailment concerns, and (v) additional description of the organization’s approach to safety.  For instance, the CPUC noted that San Diego Community Power raised concerns about the “impact[] of the COVID-19 pandemic and ramping up with long-term procurement; but [did] not explain what their exact concerns are or what the impacts of supply chain disruption could be for new renewable project development[.]”

The CPUC acknowledged that some of the deficiencies were the result of the CCA’s new status and lack of signing long term contracts for RPS resources.  Nonetheless, the CPUC was clear that it expected more responsive details and correction of the deficiencies in future filings of the following issues:

  • future plans should provide more details on their long-term contracting processes and timeframe, particularly providing a basis for potential delays related to issues raised for COVID-19 pandemic or their ability as a new CCA to meet this requirement;
  • clarifying mixed messages of noting concerns for meeting requirements due to the current pandemic, reopening of direct access market and signaling the need for a long-term contracting on-ramp, while stating that the CCAs will be able to meet the procurement requirements;
  • clarification of (i) whether over-procurement of renewables will be RPS-eligible, (ii) whether they anticipate being able to use their excess RPS resources as their MMoP, and (iii) the process they will use for adjusting their MMoP in the future as the procurement quantity requirement increases, forecasts change, and risks evolve;
  • given the 65 percent long-term contracting requirement commences in 2021, clarification of plans for how they will meet the long-term procurement requirement in Compliance Period 2021-2024.

In addition to the foregoing recommendations, which applied to all four CCAs, the CPUC also had additional recommendations directed specifically to Butte Choice Energy and the City of Santa Barbara CCA.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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