Comments at 4.) This position incorrectly relies on language in Section 399.15(b)(2)(B) that addresses years after 2030. Reid applies the word “subsequent” to the years 2016-2020, rather than the clear application of to “subsequent” mean the years following 2030.” D.16-12-040 at footnote 6. Not Verified. 6. Additional Compliance Reid argued that is not reasonable for “It “Reid’s argument Periods the Commission to attempt to plan that Commission compliance filings more than fourteen cannot set PQRs years into the future. It is important that for these the Commission maintain its flexibility to compliance adjust to changing conditions in the RPS periods because it program. Therefore, the Commission lacks authority should not establish additional compliance appears to be periods beyond 2030 because the based on the SB 2 legislature may change the RPS (1x) language of requirements after 2030 and/or may prior Section significantly change other elements of the 399.15(b)(2)(B), RPS program. Either of these changes not on SB 350’s would affect the compliance periods.” language for that (Reid SB350 Comments, p. 5) section.” Although the Commission did not adopt D.16-12-040 at recommendation, Reid made a Reid’s footnote 14. substantial contribution to the of the Additional Commission’s resolution Compliance Periods issue. 7. Procurement Quantity Reid recommended that Commission Verified “The Requirements should not treat the procurement quantity requirements (PQRs) for the three compliance periods through 2030 differently from the PQRs established for the compliance periods through 2020.”
Comments at 4.) This position incorrectly relies on language in Section 399.15(b)(2)(B) that addresses years after 2030. Reid applies the word “subsequent” to the years 2016-2020, rather than the clear application of “subsequent” to mean the years following 2030.” D.16-12-040 at footnote 6. 6. Additional Compliance Periods Reid argued that “It is not reasonable for the Commission to attempt to plan compliance filings more than fourteen years into the future. It is important that the Commission maintain its flexibility to adjust to changing conditions in the RPS program. Therefore, the Commission should not establish additional compliance periods beyond 2030 because the legislature may change the RPS requirements after 2030 and/or may significantly change other elements of the RPS program. Either of these changes would affect the compliance periods.” (Reid SB350 Comments, p. 5) Although the Commission did not adopt Reid’s recommendation, Reid made a substantial contribution to the Commission’s resolution of the Additional Compliance Periods issue. Not Verified. “Reid’s argument that Commission cannot set PQRs for these compliance periods because it lacks authority appears to be based on the SB 2 (1x) language of prior Section 399.15(b)(2)(B), not on SB 350’s language for that section.” D.16-12-040 at footnote 14. 7. Procurement Quantity Requirements Reid recommended that “The Commission should not treat the procurement quantity requirements (PQRs) for the three compliance periods through 2030 differently from the PQRs established for the compliance periods through 2020.” Verified
185718210.docx