Reports Energy Storage Track 1 Issues R. 15-03-011, pp. 4-5, Oct. 9, 2015.) Publicly Available Data 2. CEP should be Although it ultimately decided not to Verified “[T]he designed to provide side with Sierra Club and others on the transparency in an otherwise question of whether the valuation CEP’s Club data be made publicly available, the opaque process.” (Sierra Comments on Track 1 Issues, Commission discussed Sierra Club’s p. 2, July 8, 2015.) points at some length in D. 16-01-032. (See D. 16-01-032, pp. 23-25.) In comments on Track 1 Issues, Sierra Club strongly The decision, however, Commission’s advocated for the data used in was largely based on the need to keep the CEP valuation process to storage bid and confidential, “energy be publicly available, because, procurement information in order to … to and many maintain a competitive process that will date, “the public stakeholders are not privy to lead to competitive market outcomes.” the inner workings of the (See at 23.) id., Request for Offer (“RFO”) process where Investor Owned the CEP replaces market “While prices with publicly available data in Utilities (“IOUs”) establish their own proprietary valuation order to compare shortlisted projects on (Id. at 2.) an equal basis, it also contains systems.” cost data from offers received, CEP should play a which is confidential. As such, the Thus, “[t]he critical role in increasing results are also confidential and should public access to information remain covered by the confidentiality and public accountability in protocols established in D.06-06-066.” energy (See id.) California’s market.” (Id. at 2-3.) Flexibility of Energy Storage Targets Between Grid Domains 3. The Commission should not In D. 16-01-032 the Commission issued Verified modify the Energy Storage the following decision regarding issues Procurement Framework to pertaining to the flexibility of energy allow shifting of megawatts storage targets between grid domains: from or into the customer grid domain. the IOUs to evaluate and “We expect procure storage projects based on In Track 1, Sierra Club did not whether they fulfill a system need at a recommend any changes to the reasonable cost. To the extent that customer domain targets, shifting of megawatts into and out of the
Reports Energy Storage Track 1 Issues R. 15-03-011, pp. 4-5, Oct. 9, 2015.) Publicly Available Data 2. “[T]he CEP should be designed to provide transparency in an otherwise opaque process.” (Sierra Club Comments on Track 1 Issues, p. 2, July 8, 2015.) In comments on Track 1 Issues, Sierra Club strongly advocated for the data used in the CEP valuation process to be publicly available, because, to date, “the public and many stakeholders are not privy to the inner workings of the Request for Offer (“RFO”) process where Investor Owned Utilities (“IOUs”) establish their own proprietary valuation systems.” (Id. at 2.) Thus, “[t]he CEP should play a critical role in increasing public access to information and public accountability in California’s energy market.” (Id. at 2-3.) Although it ultimately decided not to side with Sierra Club and others on the question of whether the CEP’s valuation data be made publicly available, the Commission discussed Sierra Club’s points at some length in D. 16-01-032. (See D. 16-01-032, pp. 23-25.) The Commission’s decision, however, was largely based on the need to keep confidential, “energy storage bid and procurement information … in order to maintain a competitive process that will lead to competitive market outcomes.” (See id., at 23.) “While the CEP replaces market prices with publicly available data in order to compare shortlisted projects on an equal basis, it also contains cost data from offers received, which is confidential. As such, the results are also confidential and should remain covered by the confidentiality protocols established in D.06-06-066.” (See id.) Verified Flexibility of Energy Storage Targets Between Grid Domains 3. The Commission should not modify the Energy Storage Procurement Framework to allow shifting of megawatts from or into the customer grid domain. In Track 1, Sierra Club did not recommend any changes to the customer domain targets, In D. 16-01-032 the Commission issued the following decision regarding issues pertaining to the flexibility of energy storage targets between grid domains: “We expect the IOUs to evaluate and procure storage projects based on whether they fulfill a system need at a reasonable cost. To the extent that shifting of megawatts into and out of the Verified