On August 19, the California Public Utilities Commission (CPUC) issued a proposed decision accepting the 2019 Renewables Portfolio Normal Procurement Plans submitted by 4 new Neighborhood Alternative Aggregators (CCAs): Butte Alternative Vitality Authority; Clear Vitality Alliance; the Metropolis of Santa Barbara; and San Diego Neighborhood Energy. Every of those CCAs is anticipated to start out offering electrical energy to clients in 2021. As we have noted previously, San Diego’s CCA is forecasted to serve a complete load of over 6,000 GWhs, making it one of many largest CCAs in California.
Whereas the CPUC accepted, and deemed as remaining, the RPS Plans for these CCAs, the CPUC cautioned that going ahead the CCAs should submit extra detailed RPS Plans and enhance the standard of their filings. San Diego Neighborhood Energy’s RPS Plan deficiencies acknowledged by the CPUC included (i) a extra strong evaluation of danger was wanted, (ii) clarification of whether or not San Diego anticipated with the ability to use its extra renewable assets to satisfy its Minimal Margin of Procurement (MMoP), (iii) extra detailed info on the bid solicitation protocol when procurement actions start, (iv) the way it will handle curtailment issues, and (v) extra description of the group’s strategy to security. For example, the CPUC famous that San Diego Neighborhood Energy raised issues in regards to the “influence of the COVID-19 pandemic and ramping up with long-term procurement; however [did] not clarify what their actual issues are or what the impacts of provide chain disruption could possibly be for brand new renewable undertaking growth[.]”
The CPUC acknowledged that a few of the deficiencies had been the results of the CCA’s new standing and lack of signing long run contracts for RPS assets. Nonetheless, the CPUC was clear that it anticipated extra responsive particulars and correction of the deficiencies in future filings of the next points:
- future plans ought to present extra particulars on their long-term contracting processes and timeframe, significantly offering a foundation for potential delays associated to points raised for COVID-19 pandemic or their capacity as a brand new CCA to satisfy this requirement;
- clarifying combined messages of noting issues for assembly necessities as a result of present pandemic, reopening of direct entry market and signaling the necessity for a long-term contracting on-ramp, whereas stating that the CCAs will be capable to meet the procurement necessities;
- clarification of (i) whether or not over-procurement of renewables will probably be RPS-eligible, (ii) whether or not they anticipate with the ability to use their extra RPS assets as their MMoP, and (iii) the method they may use for adjusting their MMoP sooner or later because the procurement amount requirement will increase, forecasts change, and dangers evolve;
- given the 65 % long-term contracting requirement commences in 2021, clarification of plans for a way they may meet the long-term procurement requirement in Compliance Interval 2021-2024.
Along with the foregoing suggestions, which utilized to all 4 CCAs, the CPUC additionally had extra suggestions directed particularly to Butte Alternative Vitality and the Metropolis of Santa Barbara CCA.