impact of potential the future, allowing comprehensive regionalization in considering out-of-state resource competition to targets and resources necessary Decision at serve California needs.” to meet those goals. 62. 11. EDF contended that an in support of the Verified “Parties generally increased Renewable Portfolio idea of raising the RPS compliance Standard was imminently requirement across the board achievable and that failure to included AWEA, CEERT, EDF, consider a higher RPS could IEP, National Grid, and Vote Solar.” underestimate renewable Decision at 76. energy penetration, thereby pointed out that raising the “EDF falsely relying on natural gas RPS would help us get out in front as a necessary resource for of legislative action that may require reliability. the same thing. However, they urged caution in requiring additional investment in utility-scale renewables, preferring additional DER development to avoid unnecessary or stranded uneconomic Decision at 78-79. investment.” 12. EDF theoretically parties supported the GHG “Many supported inclusion of a GHG emissions benchmark proposed by benchmark for load-serving staff, either instead of or in addition entities, provided that to the GHG Planning Price. contemplated GHG reductions Generally supportive parties were sufficiently ambitious. included AEE, CEERT, CESA, EDF, NRDC, ORA, SCE, Tesla, UCAN, and Decision at 99. UCS.” 13. EDF supported use of the parties generally Verified “Numerous Common Resource Valuation supported the idea of creation of a Methodology (CRVM) as way CRVM, including PG&E, SCE, to model performance AEE, CEJA/Sierra Club, EDF, characteristics of a wide NRG, NRDC, Tesla, AWEA, Vote variety of resources, including Solar, Ormat, and CEERT.” dynamic retail rates and DERs; Decision at 115. as well, EDF believes the CRVM could be used as a template in related proceeding. 14. EDF supports further study parties commented on Verified “Numerous of the impact of the IRP this aspect of the staff process on the natural gas fleet, recommendation. Some fundamental stating that the Commission needs raised by parties included the needs to examine how to retire need for better location-specific natural gas plants currently understanding of the value of natural
impact of potential regionalization in considering targets and resources necessary to meet those goals. the future, allowing comprehensive out-of-state resource competition to serve California needs.” Decision at 62. 11. EDF contended that an increased Renewable Portfolio Standard was imminently achievable and that failure to consider a higher RPS could underestimate renewable energy penetration, thereby falsely relying on natural gas as a necessary resource for reliability. “Parties generally in support of the idea of raising the RPS compliance requirement across the board included AWEA, CEERT, EDF, IEP, National Grid, and Vote Solar.” Decision at 76. “EDF pointed out that raising the RPS would help us get out in front of legislative action that may require the same thing. However, they urged caution in requiring additional investment in utility-scale renewables, preferring additional DER development to avoid unnecessary or stranded uneconomic investment.” Decision at 78-79. Verified 12. EDF theoretically supported inclusion of a GHG benchmark for load-serving entities, provided that contemplated GHG reductions were sufficiently ambitious. “Many parties supported the GHG emissions benchmark proposed by staff, either instead of or in addition to the GHG Planning Price. Generally supportive parties included AEE, CEERT, CESA, EDF, NRDC, ORA, SCE, Tesla, UCAN, and UCS.” Decision at 99. 13. EDF supported use of the Common Resource Valuation Methodology (CRVM) as way to model performance characteristics of a wide variety of resources, including dynamic retail rates and DERs; as well, EDF believes the CRVM could be used as a template in related proceeding. “Numerous parties generally supported the idea of creation of a CRVM, including PG&E, SCE, AEE, CEJA/Sierra Club, EDF, NRG, NRDC, Tesla, AWEA, Vote Solar, Ormat, and CEERT.” Decision at 115. Verified 14. EDF supports further study of the impact of the IRP process on the natural gas fleet, stating that the Commission needs to examine how to retire natural gas plants currently “Numerous parties commented on this aspect of the staff recommendation. Some fundamental needs raised by parties included the need for better location-specific understanding of the value of natural Verified