reflect these CPUCapproved changes. IEPA SDG&E IEPA We reject Comments at comments that this comment. 1819. SDG&E's LongTerm Deliverability PPA appears to status is being only contemplate addressed in the projects with Full LCBF Reform Capacity track in this Deliverability Status proceeding. A (FCDS), which would requirement for appear to send a FCDS was market signal that previously denied EnergyOnly (EO) in D.1104030 (at projects won't be 20), which clearly considered. IEP allows EO recommends projects to be SDG&E's Model PPA considered in RPS be modified to clarify solicitations. which role, if any, EO projects can play in an RPS solicitation. IEPA PG&E, SCE, IEPA, LSA and As argued Comments at 5; and SDG&E CalWEA argue that by ORA (Reply LSA Comments the IOUs should be Comments at 2), at 3; CalWEA required to excel and SCE (Reply Reply exceed SB 350’s Comments at 3), Comments at 3. targets to take and PG&E (Reply advantage of current Comments at 4), economic conditions. the utilities have Specifically, these already parties argue that established delaying RPS margins of procurement risks procurement, higher ratepayer costs without the use of
reflect these CPUCapproved changes. IEPA Comments at 1819. SDG&E IEPA comments that SDG&E's LongTerm PPA appears to only contemplate projects with Full Capacity Deliverability Status (FCDS), which would appear to send a market signal that EnergyOnly (EO) projects won't be considered. IEP recommends SDG&E's Model PPA be modified to clarify which role, if any, EO projects can play in an RPS solicitation. We reject this comment. Deliverability status is being addressed in the LCBF Reform track in this proceeding. A requirement for FCDS was previously denied in D.1104030 (at 20), which clearly allows EO projects to be considered in RPS solicitations. IEPA Comments at 5; LSA Comments at 3; CalWEA Reply Comments at 3. PG&E, SCE, and SDG&E IEPA, LSA and CalWEA argue that the IOUs should be required to excel and exceed SB 350’s targets to take advantage of current economic conditions. Specifically, these parties argue that delaying RPS procurement risks higher ratepayer costs As argued by ORA (Reply Comments at 2), SCE (Reply Comments at 3), and PG&E (Reply Comments at 4), the utilities have already established margins of procurement, without the use of
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