generation as part of its Sierra Club conclude that the preferred resource minimum Commission must reject these contracts neither qualify as demand as not qualifying toward the minimum response nor distributed Preferred Resources procurement generation and must be requirement in D.13-02-015 and rejected. Sierra Club issued (Decision p. 14) data requests, conducted to Sierra Club and ORA, “According examination, and significantly all seven of these contracts fail to briefed this issue. (See, e.g., qualify as Demand Response contracts Sierra Club Opening Br. 4-10; or even Preferred Resources contracts Sierra Club Reply Br. 2-4). on the basis that total load reduction is D.15- 11-041 agreed with not achieved and fossil fuel is relied Sierra Club arguments and (Decision p. 15) upon.” rejected these contracts. Club further states that the “Sierra contracts do not qualify as Demand Response or Preferred Resources because they rely on reciprocating engines to support load during a (Decision p. 15) curtailment.” that these contracts fail to “We find constitute Preferred Resources because they rely on natural gas-fired BTM generation to reduce the amount of energy served by the (Decision p. grid.” 17.) 2. 100 MW Storage Cap and part of the RFO for the Western LA Verified “As Resulting Procurement of 98 Basin, SCE did not consider bids for in MW Stanton Peaker Plant. front of the (IFOM) Energy Sierra Club opposed Storage above 100 MW. ORA, Powers SCE’s decision to cap Engineering, and Sierra Club argue the meter (IFOM) energy storage cap is unjustified and arbitrary.” at 100 MW and as a result of (Decision p. 18) that cap, procure a more costly Club further suggests it is “Sierra peaker plant. Sierra Club unreasonable, unsupported by facts, and submitted expert testimony on results in the proposed procurement that this issue following several violates the Loading Order. Sierra data requests, conducted further asserts that, as a direct Club significant cross result of the artificial 100 MW cap on and briefed the issue, arguing IFOM Energy Storage, SCE selected the that procurement of SCE’s gas-fired Stanton Energy Reliability Stanton was unreasonable, Center (Stanton), a choice which was unsupported and violated the inconsistent with the loading order and Loading Order and Least
generation as part of its preferred resource minimum neither qualify as demand response nor distributed generation and must be rejected. Sierra Club issued data requests, conducted and significantly briefed this issue. (See, e.g., Sierra Club Opening Br. 4-10; Sierra Club Reply Br. 2-4). D.15- 11-041 agreed with Sierra Club arguments and rejected these contracts. Sierra Club conclude that the Commission must reject these contracts as not qualifying toward the minimum Preferred Resources procurement requirement in D.13-02-015 and (Decision p. 14) “According to Sierra Club and ORA, all seven of these contracts fail to qualify as Demand Response contracts or even Preferred Resources contracts on the basis that total load reduction is not achieved and fossil fuel is relied upon.” (Decision p. 15) “Sierra Club further states that the contracts do not qualify as Demand Response or Preferred Resources because they rely on reciprocating engines to support load during a curtailment.” (Decision p. 15) “We find that these contracts fail to constitute Preferred Resources because they rely on natural gas-fired BTM generation to reduce the amount of energy served by the grid.” (Decision p. 17.) 2. 100 MW Storage Cap and Resulting Procurement of 98 MW Stanton Peaker Plant. Sierra Club opposed SCE’s decision to cap (IFOM) energy storage at 100 MW and as a result of that cap, procure a more costly peaker plant. Sierra Club submitted expert testimony on this issue following several data requests, conducted significant cross examination, and briefed the issue, arguing that SCE’s procurement of Stanton was unreasonable, unsupported and violated the Loading Order and Least “As part of the RFO for the Western LA Basin, SCE did not consider bids for in front of the meter (IFOM) Energy Storage above 100 MW. ORA, Powers Engineering, and Sierra Club argue the cap is unjustified and arbitrary.” (Decision p. 18) “Sierra Club further suggests it is unreasonable, unsupported by facts, and results in the proposed procurement that violates the Loading Order. Sierra Club further asserts that, as a direct result of the artificial 100 MW cap on IFOM Energy Storage, SCE selected the gas-fired Stanton Energy Reliability Center (Stanton), a choice which was inconsistent with the loading order and Verified