In this consolidated proceeding, parties served testimony and filed briefs prior to the interim RIC adder set in R.11-05-005. In December 2014, parties were invited to brief whether (and how) the RIC adder developed in R.11-05-005 should be applied to GTSR customers. ORA and other parties argue that the interim RIC adder should be used to calculate a RIC charge applicable to GTSR customers from the start of the program. In contrast, SDG&E argues that the RIC adder is intended to be used for bid evaluation, not for allocating the cost of renewables integration. There is no record in this proceeding regarding whether the Commission will ultimately determine that renewable integration costs should be collected from the renewable energy provider or from ratepayers. Because the RIC adder from D.14-11-042 is being used on a going forward basis, there is no methodology for determining the RIC for existing projects. If a RIC charge is applied to GTSR customers on a volumetric basis instead to the power producer, we cannot assume that the RIC charge will collect the full cost of renewables integration for each facility. If a GTSR facility is not fully subscribed, and the renewable integration cost for the facility is to be borne by the GTSR customers, the calculation of a fair RIC would be complex. Aside from SDG&E, the parties have not addressed a circumstance such as this one, where a value has been set for a RIC adder, but the Commission has not indicated to whom or the how the costs should be allocated. SDG&E, PG&E and the Settling Parties argue against applying the RIC charge to GTSR participants that sign up prior establishment of the RIC charge. The cost of renewables integration is an important procurement issue that is still being addressed at the Commission. It is likely that a RIC charge can be calculated in the near future based on Commission directions. In the meantime,
In this consolidated proceeding, parties served testimony and filed briefs prior to the interim RIC adder set in R.11-05-005. In December 2014, parties were invited to brief whether (and how) the RIC adder developed in R.11-05-005 should be applied to GTSR customers. ORA and other parties argue that the interim RIC adder should be used to calculate a RIC charge applicable to GTSR customers from the start of the program. In contrast, SDG&E argues that the RIC adder is intended to be used for bid evaluation, not for allocating the cost of renewables integration. There is no record in this proceeding regarding whether the Commission will ultimately determine that renewable integration costs should be collected from the renewable energy provider or from ratepayers. Because the RIC adder from D.14-11-042 is being used on a going forward basis, there is no methodology for determining the RIC for existing projects. If a RIC charge is applied to GTSR customers on a volumetric basis instead to the power producer, we cannot assume that the RIC charge will collect the full cost of renewables integration for each facility. If a GTSR facility is not fully subscribed, and the renewable integration cost for the facility is to be borne by the GTSR customers, the calculation of a fair RIC would be complex. Aside from SDG&E, the parties have not addressed a circumstance such as this one, where a value has been set for a RIC adder, but the Commission has not indicated to whom or the how the costs should be allocated. SDG&E, PG&E and the Settling Parties argue against applying the RIC charge to GTSR participants that sign up prior establishment of the RIC charge. The cost of renewables integration is an important procurement issue that is still being addressed at the Commission. It is likely that a RIC charge can be calculated in the near future based on Commission directions. In the meantime,
146250314.docx