transmission and distribution domains where market/bundled services may most likely reside. Proposed projects related to generation/market “bundled” services for the 2014-2016 solicitation (that could be eligible for and apply for PCIA treatment) are more difficult to forecast and depend on multiple factors (e.g., storage configuration of newly eligible technologies that provide market services (all or in part)), many of which are not yet known. Cost recovery of bundled service storage projects is subject to approval by the Commission on a case-by-case basis through an Application or Tier 3 Advice Letter process as appropriate to the applicable proceeding. In the early stages of the energy storage program, we do not know the potential PCIA-related projects beyond those existing projects that have already been deemed eligible for PCIA treatment. Implementing actual PCIA cost recovery may be challenging because a benchmark to quantify above market storage costs has not yet been developed. Predicting the extent to which “departing load” will be an issue in the future may be difficult; for example, DA is maxed out under load caps as prescribed by Senate Bill (SB) 695 (Stats, 2009, Ch. 337). Departing load due to CCAs appears to be in a state of growth; however, further evidence is needed to substantiate this. It is not clear whether load departing from IOU “bundled” service will result in stranded costs attributable to IOU energy storage procurement. Potential implementation of PCIA for generation and non-generation in future energy storage solicitations involves complex policy, equity, cost,
transmission and distribution domains where market/bundled services may most likely reside. Proposed projects related to generation/market “bundled” services for the 2014-2016 solicitation (that could be eligible for and apply for PCIA treatment) are more difficult to forecast and depend on multiple factors (e.g., storage configuration of newly eligible technologies that provide market services (all or in part)), many of which are not yet known. Cost recovery of bundled service storage projects is subject to approval by the Commission on a case-by-case basis through an Application or Tier 3 Advice Letter process as appropriate to the applicable proceeding. In the early stages of the energy storage program, we do not know the potential PCIA-related projects beyond those existing projects that have already been deemed eligible for PCIA treatment. Implementing actual PCIA cost recovery may be challenging because a benchmark to quantify above market storage costs has not yet been developed. Predicting the extent to which “departing load” will be an issue in the future may be difficult; for example, DA is maxed out under load caps as prescribed by Senate Bill (SB) 695 (Stats, 2009, Ch. 337). Departing load due to CCAs appears to be in a state of growth; however, further evidence is needed to substantiate this. It is not clear whether load departing from IOU “bundled” service will result in stranded costs attributable to IOU energy storage procurement. Potential implementation of PCIA for generation and non-generation in future energy storage solicitations involves complex policy, equity, cost,
127426247.docx