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Parties Filed Comments On Implementation Of The Community Renewable Energy Program
The Utility Reform Network (TURN) said “Reliance on ReMAT and PURPA without modifications is unlikely to yield successful new project development.”
Solar Energy Industries Association (SEIA) argued that “External funding is needed to supplement PPA revenues to support project costs,” especially given that the decision identified “No revenue source for non-low-income subscriber credits,”
Coalition for Community Solar Access (CCSA) also argued with respect to funding for low-income subscribers that “the reliance on limited, one-time funding sources injects significant uncertainty into the long-term viability” of the CREP;
Joint Community Choice Aggregators and City and County of San Fransisco (Joint CCAs) recommended that PPA’s should be for 20-year delivery terms, a significant increase from the 12-year terms of PURPA standard offer contracts (SOCs).
Dimension Renewable Energy argued that “[e]ven without the complications of applying [Solar for All (SFA)] requirements to existing tariffs, the outdated ReMAT lacks the price signals to support solar + storage projects and does not assure projects deliver during peak hours,” with SEIA noting that “The ReMAT as- available peaking price that would be used for the CREP is based on a sample of solar-only RPS projects with capacities below 20 MW” and thus “is inadequate to support the higher costs of solar-plus-storage projects that offer more value to the system”.
SEIA proposed a structure that begins with a 20-year ReMAT PPA, updated “to recognize the time-varying value of renewable generation,” with solar + storage projects “eligible for a ratepayer- funded Capacity Adder that is based on the avoided generation capacity costs for the project’s storage component” and all projects should receiving a Project Adder covering remaining developer costs and non-low-income subscriber credits, while Joint CCAs “believe the CRE Program should be based on SOCs because this contract structure allows the developers insight into PPA prices, which in turn helps them assess the feasibility of project development,” with the base payment based on PURPA avoided costs, “with additional “adders” provided to appropriately value the local DERs,”
In addition, Cal Advocates and TURN proposed reverse auction, with TURN explaining that its structure “uses ReMAT/PURPA pricing as a starting point but incorporates several additional elements that will optimally use external funding, recognize and capture the value of storage, and introduce a competitive process through a reverse auction to minimize resource cost.”
Reply comments were due July 17, 2024.
A2205023 (Opened 05/31/2022)
Review of SDG&E’s Disadvantaged Communities – Green Tariff (DAC-GT) and Community Solar Green Tariff (CS-GT) programs (collectively, the “DAC Programs”).
Natural Gas – Default Service
