as tax credits bank, and each diminish over time. are in a position IEPA's analysis to exceed their (using RPS Calculator RPS procurement v.6.2) demonstrates requirements. that the reduction in Given this, along federal tax incentives with the between 20192022 uncertainty increases the associated with levelized costs for longterm market solar projects by 25% conditions and and wind projects by future load, we 13%. will not require the IOUs to In addition, CalWEA increase their argues that the ability procurement to obtain federal tax obligations benefits will greatly beyond the improve the minimum targets economic established by competitiveness of statute at this wind repowers for time. qualifying facility contracts that are about to expire. Joint ESPs/CCAs The Joint Utilities As noted by Utilities comment that the AReM (Reply (SDG&E, PG&E, modifications to law Comments at 2), and SCE) enacted by SB 350 the Commission Comments at 12 require all retail has previously sellers to prepare and determined that submit RPS Plans that ESPs and CCAs address the should not be requirements in PU required to follow Code 399.13(a)(1) and the exact same also require CCAs to steps for RPS
as tax credits diminish over time. IEPA's analysis (using RPS Calculator v.6.2) demonstrates that the reduction in federal tax incentives between 20192022 increases the levelized costs for solar projects by 25% and wind projects by 13%. In addition, CalWEA argues that the ability to obtain federal tax benefits will greatly improve the economic competitiveness of wind repowers for qualifying facility contracts that are about to expire. bank, and each are in a position to exceed their RPS procurement requirements. Given this, along with the uncertainty associated with longterm market conditions and future load, we will not require the IOUs to increase their procurement obligations beyond the minimum targets established by statute at this time. Joint Utilities (SDG&E, PG&E, and SCE) Comments at 12 ESPs/CCAs The Joint Utilities comment that the modifications to law enacted by SB 350 require all retail sellers to prepare and submit RPS Plans that address the requirements in PU Code 399.13(a)(1) and also require CCAs to As noted by AReM (Reply Comments at 2), the Commission has previously determined that ESPs and CCAs should not be required to follow the exact same steps for RPS
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