includes a limited volume of procurement associated with new programs, such as the GTSR Program, that reflect the changing needs of its customers. ORA asserts that VMOP is not a sufficient mitigation if GTSR provides SDG&E with undue discretion for using its VMOP to procure excess RPS resources. ORA observes that, in general, the IOUs have some degree of flexibility to specify the methodology for determining their own VMOPs, and therefore the VMOP does not appear to be a meaningful tool for addressing the risk of overprocurement to non-participating ratepayers. SCE proposes to rely on excess RPS generation for its GTSR Program. By doing so, SCE would minimize the risk of overprocurement of GTSR-specific resources. However, as discussed above, SCE’s proposal is not compliant with SB 43 and this decision directs SCE to focus on procuring new renewable generation for GTSR Program. As directed by SB 43, SCE should apply any GTSR overprocurement to the RPS program in accordance with this decision. The IOUs should use the RPS backstop method as required by statute. The clear language of the statute requires that the RPS backstop be used for overprocurement, regardless of whether the overprocurement is the result of customer attrition or “other causes.” This approach is reasonable and efficient. The GTSR Program is small compared to the overall RPS program. Currently, 600 MW would represent less than 6% of current RPS capacity online. Because the GTSR Program is very small in comparison to RPS, transferring overprocurement to RPS would not result in unjust or unreasonable rates for ratepayers. Because it is difficult to calculate all of the net impacts on non-participants, direct comparison of average prices, as suggested by ORA, is not the right tool. No party has identified a reasonable, practicable, definitive method for determining a price difference.
includes a limited volume of procurement associated with new programs, such as the GTSR Program, that reflect the changing needs of its customers. ORA asserts that VMOP is not a sufficient mitigation if GTSR provides SDG&E with undue discretion for using its VMOP to procure excess RPS resources. ORA observes that, in general, the IOUs have some degree of flexibility to specify the methodology for determining their own VMOPs, and therefore the VMOP does not appear to be a meaningful tool for addressing the risk of overprocurement to non-participating ratepayers. SCE proposes to rely on excess RPS generation for its GTSR Program. By doing so, SCE would minimize the risk of overprocurement of GTSR-specific resources. However, as discussed above, SCE’s proposal is not compliant with SB 43 and this decision directs SCE to focus on procuring new renewable generation for GTSR Program. As directed by SB 43, SCE should apply any GTSR overprocurement to the RPS program in accordance with this decision. The IOUs should use the RPS backstop method as required by statute. The clear language of the statute requires that the RPS backstop be used for overprocurement, regardless of whether the overprocurement is the result of customer attrition or “other causes.” This approach is reasonable and efficient. The GTSR Program is small compared to the overall RPS program. Currently, 600 MW would represent less than 6% of current RPS capacity online. Because the GTSR Program is very small in comparison to RPS, transferring overprocurement to RPS would not result in unjust or unreasonable rates for ratepayers. Because it is difficult to calculate all of the net impacts on non-participants, direct comparison of average prices, as suggested by ORA, is not the right tool. No party has identified a reasonable, practicable, definitive method for determining a price difference.
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