no party criticizing the backstop brief of TURN on the Application of has offered a workable method for SCE for approval of a Green Tariff Shared calculating the net rate impacts. Renewables Program, May 9, 2014, pages The Decision agrees that SB 43 3-4 requires utilities to use the RPS backstop method for any overprocurement on behalf of GTSR subscribers. The Decision further agrees with TURN that the D.15-01-051, pages 47-50. determination of net impacts on non-participants is difficult and that no party has identified a practicable, “reasonable, definitive method for determining a price difference.” 6. PROCUREMENT / SCE PROPOSAL TO SATISFY ADDITIONALITY TURN urged the Commission to Direct Testimony of Matthew Freedman on Verified. reject SCE’s procurement and the Green Rate Application of SCE, April portfolio proposal as unreasonable 11, 2014, pages 2-6, 8-11 and inconsistent with SB 43. TURN argued that the proposal Opening brief of TURN on the Application fails the additionality test and of SCE for approval of a Green Tariff would not produce any Shared Renewables Program, May 2, 2014, incremental renewable power to pages 3-16 serve subscribers. TURN urged the Commission to require dedicated procurement comparable to the approaches proposed by PG&E and SDG&E. The Decision agrees with TURN and finds that SCE’s proposal to meet the additionality D.15-01-051, pages 25-26 “fails requirements of SB 43”. The Decision requires SCE to restructure its GTSR program to promote additional resources consistent with the approaches approved for SDG&E and PG&E. 7. ENHANCED COMMUNITY RENEWABLES / CITY OF DAVIS Opening brief of TURN on the Enhanced Verified. TURN argued that SB 43 does not Community Renewables Proposal of authorize the City of Davis to PG&E, May 5, 2014, pages 7-8 administer its own GTSR program and does not allow for the bill
no party criticizing the backstop has offered a workable method for calculating the net rate impacts. The Decision agrees that SB 43 requires utilities to use the RPS backstop method for any overprocurement on behalf of GTSR subscribers. The Decision further agrees with TURN that the determination of net impacts on non-participants is difficult and that no party has identified a “reasonable, practicable, definitive method for determining a price difference.” brief of TURN on the Application of SCE for approval of a Green Tariff Shared Renewables Program, May 9, 2014, pages 3-4 D.15-01-051, pages 47-50. 6. PROCUREMENT / SCE PROPOSAL TO SATISFY ADDITIONALITY TURN urged the Commission to reject SCE’s procurement and portfolio proposal as unreasonable and inconsistent with SB 43. TURN argued that the proposal fails the additionality test and would not produce any incremental renewable power to serve subscribers. TURN urged the Commission to require dedicated procurement comparable to the approaches proposed by PG&E and SDG&E. The Decision agrees with TURN and finds that SCE’s proposal “fails to meet the additionality requirements of SB 43”. The Decision requires SCE to restructure its GTSR program to promote additional resources consistent with the approaches approved for SDG&E and PG&E. Direct Testimony of Matthew Freedman on the Green Rate Application of SCE, April 11, 2014, pages 2-6, 8-11 Opening brief of TURN on the Application of SCE for approval of a Green Tariff Shared Renewables Program, May 2, 2014, pages 3-16 D.15-01-051, pages 25-26 Verified. 7. ENHANCED COMMUNITY RENEWABLES / CITY OF DAVIS TURN argued that SB 43 does not authorize the City of Davis to administer its own GTSR program and does not allow for the bill Opening brief of TURN on the Enhanced Community Renewables Proposal of PG&E, May 5, 2014, pages 7-8 Verified.
167744132.docx