The course of these two federal policies suggests caution in assuming that the current policy environment will continue indefinitely. This history provides an additional reason for the Commission’s commitment to review the NEM successor tariff in 2019. The Public Tool Developed by Energy Division staff with consultants, the Public Tool is intended to provide a vetted, neutral platform on which all party proposals may be tested and compared on an to apples” basis. The Public Tool is not “apples intended to generate answer” to any policy questions about the NEM “the successor tariff. The Energy Division Tariff Paper provided representative uses of the Public Tool and modeled how to use it. Parties were also allowed by the ALJ’s Proposal Ruling to make changes to inputs and assumptions and of the “states world” in their use of the Public Tool, so long as those changes were properly documented. Because of both limitations of the internal logic of the Public Tool, and uncertainty about the external conditions in the world in the future, the Staff Tariff Paper used two scenarios: one in which customer-sited “bookend” renewable DG is postulated to have a value to all customers, and one in “high” which customer-sited renewable DG is postulated to have a value to all “low” customers. Parties used these to evaluate their proposals. Some “bookends” parties also took advantage of the opportunity to create a third, customized scenario.
The course of these two federal policies suggests caution in assuming that the current policy environment will continue indefinitely. This history provides an additional reason for the Commission’s commitment to review the NEM successor tariff in 2019. The Public Tool Developed by Energy Division staff with consultants, the Public Tool is intended to provide a vetted, neutral platform on which all party proposals may be tested and compared on an “apples to apples” basis. The Public Tool is not intended to generate “the answer” to any policy questions about the NEM successor tariff. The Energy Division Tariff Paper provided representative uses of the Public Tool and modeled how to use it. Parties were also allowed by the ALJ’s Proposal Ruling to make changes to inputs and assumptions and “states of the world” in their use of the Public Tool, so long as those changes were properly documented. Because of both limitations of the internal logic of the Public Tool, and uncertainty about the external conditions in the world in the future, the Staff Tariff Paper used two “bookend” scenarios: one in which customer-sited renewable DG is postulated to have a “high” value to all customers, and one in which customer-sited renewable DG is postulated to have a “low” value to all customers. Parties used these “bookends” to evaluate their proposals. Some parties also took advantage of the opportunity to create a third, customized scenario.
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