GTSR customers benefit from rate certainty because their rates have less relationship to volatile fuel costs than other customers. Providing assurance of bid acceptance will increase developer interest in ECR projects. 120% of expected annual load is a reasonable approximation by which to set a customer’s 100% of energy demand for purposes of ECR subscriptions. To ensure reasonable rates and fulfill the purpose of the ECR component of the GTSR Program it is necessary to ensure that ECR projects achieve and maintain a reasonable minimum subscription capacity. Setting a lower price for unsubscribed energy from ECR projects will incentivize developers to achieve and maintain reasonable minimum subscription capacity. The lesser of the DLAP price or the PPA price is a reasonable proxy for the market value of unsubscribed ECR project energy transferred to an IOU. Unsubscribed ECR project energy must be transferred with the associated RECs. In the event that RECs associated with unsubscribed ECR project energy are transferred to an IOU at the DLAP price, the developer should be compensated for the market value of the REC, however in no event should this combined amount exceed the PPA price. A method for determining the market value of the REC for unsubscribed ECR energy that is transferred to the IOU has not been considered in this proceeding. ECR projects where customers own or control an interest in the project or company owning the project could constitute a security subject to state and/or federal regulation.
GTSR customers benefit from rate certainty because their rates have less relationship to volatile fuel costs than other customers. Providing assurance of bid acceptance will increase developer interest in ECR projects. 120% of expected annual load is a reasonable approximation by which to set a customer’s 100% of energy demand for purposes of ECR subscriptions. To ensure reasonable rates and fulfill the purpose of the ECR component of the GTSR Program it is necessary to ensure that ECR projects achieve and maintain a reasonable minimum subscription capacity. Setting a lower price for unsubscribed energy from ECR projects will incentivize developers to achieve and maintain reasonable minimum subscription capacity. The lesser of the DLAP price or the PPA price is a reasonable proxy for the market value of unsubscribed ECR project energy transferred to an IOU. Unsubscribed ECR project energy must be transferred with the associated RECs. In the event that RECs associated with unsubscribed ECR project energy are transferred to an IOU at the DLAP price, the developer should be compensated for the market value of the REC, however in no event should this combined amount exceed the PPA price. A method for determining the market value of the REC for unsubscribed ECR energy that is transferred to the IOU has not been considered in this proceeding. ECR projects where customers own or control an interest in the project or company owning the project could constitute a security subject to state and/or federal regulation.
146250314.docx