Comments on Peterman APD pp. 3-5 (Mar. 3, 2016; Sierra Club Reply Comments on Peterman APD pp. 1-2 (Mar. 8, 2016)). the Decision found authority cited by Sierra Club was not binding on the Moorpark procurement, the Decision was significantly revised from the initial Peterman APD to call for explicit consideration of environmental justice in review of future procurement contracts. 3. Procurement of Ellwood From Decision p. 28: project does Yes, Sierra Club’s “the Invalid in New Source RFO. not fall within the definition of participation aided in incremental resource and, the terms the Commission’s Sierra Club argued that the of the Commission’s prior decisions, the decisionmaking on Application’s proposed 54 MW contract to refurbish the this issue. Sierra procurement of an extended Ellwood facility does not count toward Club presented issues contract for the existing 54 the LCR procurement authorization with the proposed MW Ellwood peaker paired required in D.13-12-015 (citing to Sierra procurement that with 0.5 MW of new energy Club Opening Br. at 5-6). allowed Commission storage violated recently decisionmakers to adopted procurement rules in make a more D.14-02-040 limiting bids in informed position. new resource RFOs to incremental resources only. (See, (Sierra Club Opening e.g. Br. pp. 5-7 (July 22, 2015); Sierra Club Opening Comments on PD/APD pp. 5-7 (Feb. 1, 2016); Sierra Club Opening Comments on Peterman APD pp. 10-11 (Mar. 3, 2016)). The Decision requires further Sierra Club also argued that consideration of whether Ellwood is the approving an extended contract best resource to meet any unmet local with an existing fossil-fuel reliability need. (Decision pp. 31-32). prior to a consideration of
Comments on Peterman APD pp. 3-5 (Mar. 3, 2016; Sierra Club Reply Comments on Peterman APD pp. 1-2 (Mar. 8, 2016)). the Decision found authority cited by Sierra Club was not binding on the Moorpark procurement, the Decision was significantly revised from the initial Peterman APD to call for explicit consideration of environmental justice in review of future procurement contracts. 3. Procurement of Ellwood Invalid in New Source RFO. Sierra Club argued that the Application’s proposed procurement of an extended contract for the existing 54 MW Ellwood peaker paired with 0.5 MW of new energy storage violated recently adopted procurement rules in D.14-02-040 limiting bids in new resource RFOs to incremental resources only. (See, e.g. (Sierra Club Opening Br. pp. 5-7 (July 22, 2015); Sierra Club Opening Comments on PD/APD pp. 5-7 (Feb. 1, 2016); Sierra Club Opening Comments on Peterman APD pp. 10-11 (Mar. 3, 2016)). Sierra Club also argued that approving an extended contract with an existing fossil-fuel prior to a consideration of From Decision p. 28: “the project does not fall within the definition of incremental resource and, the terms of the Commission’s prior decisions, the 54 MW contract to refurbish the Ellwood facility does not count toward the LCR procurement authorization required in D.13-12-015 (citing to Sierra Club Opening Br. at 5-6). The Decision requires further consideration of whether Ellwood is the best resource to meet any unmet local reliability need. (Decision pp. 31-32). Yes, Sierra Club’s participation aided in the Commission’s decisionmaking on this issue. Sierra Club presented issues with the proposed procurement that allowed Commission decisionmakers to make a more informed position.
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