renewable energy developers and other stakeholders to encourage sound policies through a Renewable Energy Working Group, an informal and diverse group working to protect ecosystems, landscapes and species, while supporting the development of energy resources in the California desert and other suitable locations. PG&E believes that longterm and comprehensive planning and permitting processes can help better inform and facilitate renewable development. Transmission and Interconnection PG&E observes that delays in achieving interconnection can occur for various reasons, including the delay of substation construction, permitting issues, telecommunications delays, or overly aggressive timeline assumptions. While delays in interconnection can lead to delays in project development, such delays to date have not had a major impact on PG&E’s ability to meet its RPS procurement targets. Curtailment of RPS Generating Resources In PG&E’s view, if RPS curtailed volumes increase substantially due to CAISO market or reliability conditions, curtailment may present an RPS compliance challenge. In order to better address this challenge, PG&E’s stochastic model incorporates estimated levels of curtailment, which enables PG&E to plan for appropriate levels of RPS procurement to meet RPS compliance even when volumes are curtailed. Risk Assessment Dynamic risks directly affect PG&E’s ability to plan for and meet compliance with the RPS requirements. To account for these and additional
renewable energy developers and other stakeholders to encourage sound policies through a Renewable Energy Working Group, an informal and diverse group working to protect ecosystems, landscapes and species, while supporting the development of energy resources in the California desert and other suitable locations. PG&E believes that longterm and comprehensive planning and permitting processes can help better inform and facilitate renewable development. Transmission and Interconnection PG&E observes that delays in achieving interconnection can occur for various reasons, including the delay of substation construction, permitting issues, telecommunications delays, or overly aggressive timeline assumptions. While delays in interconnection can lead to delays in project development, such delays to date have not had a major impact on PG&E’s ability to meet its RPS procurement targets. Curtailment of RPS Generating Resources In PG&E’s view, if RPS curtailed volumes increase substantially due to CAISO market or reliability conditions, curtailment may present an RPS compliance challenge. In order to better address this challenge, PG&E’s stochastic model incorporates estimated levels of curtailment, which enables PG&E to plan for appropriate levels of RPS procurement to meet RPS compliance even when volumes are curtailed. Risk Assessment Dynamic risks directly affect PG&E’s ability to plan for and meet compliance with the RPS requirements. To account for these and additional