issue, the GPI made a flexible ramping resources, under a 50 substantial contribution by percent Renewable Portfolio Standard, helping to enrich the record citing various modeling work and upon which the studies undertaken by CAISO, E3, Commission’s decision was based, and we Union of Concerned Scientists, and the note that the Decision provides Low-Carbon Grid Study. [D.17-04-039, an opening to adopt our pg. 15.] approach in the future. We do not lose sight of the market transformation objectives of the energy storage targets, however, and may reconsider whether to increase the targets in a future rulemaking after the results from the 2016 Storage Evaluation process become available. To be clear, while we do not modify the targets, we view them as the minimum cost-effective energy storage resources that the utilities must procure, not the maximum. [D.17-04-039, pg. 18.] Pleadings We also urge the Commission to consider 2025 and 2030 procurement targets in light of the new RPS under SB 350. [GPI Comments, 2/5/16, pg. 2.] We support a workshop to consider various options for increasing the ESP targets. We preliminarily support Sierra for an Club’s recommendation additional 3,000 megawatts of storage. [GPI Reply Comments, 2/22/16, pg. 2.] If the Commission approves a higher ESP target, we suggest a four-part revised ESP structure that acknowledges natural divisions between scale and technology types: 1) community storage of all types (1 MW and smaller); 2) medium-scale storage of all types (1-20 MW); 3) large storage of all types MW); 4) bulk storage (50 MW and up for hydro and other large-scale storage technologies). [GPI Reply Comments, 2/22/16, pg. 2.]
issue, the GPI made a substantial contribution by helping to enrich the record upon which the Commission’s decision was based, and we note that the Decision provides an opening to adopt our approach in the future. flexible ramping resources, under a 50 percent Renewable Portfolio Standard, citing various modeling work and studies undertaken by CAISO, E3, Union of Concerned Scientists, and the Low-Carbon Grid Study. [D.17-04-039, pg. 15.] We do not lose sight of the market transformation objectives of the energy storage targets, however, and may reconsider whether to increase the targets in a future rulemaking after the results from the 2016 Storage Evaluation process become available. To be clear, while we do not modify the targets, we view them as the minimum cost-effective energy storage resources that the utilities must procure, not the maximum. [D.17-04-039, pg. 18.] Pleadings We also urge the Commission to consider 2025 and 2030 procurement targets in light of the new RPS under SB 350. [GPI Comments, 2/5/16, pg. 2.] We support a workshop to consider various options for increasing the ESP targets. We preliminarily support Sierra Club’s recommendation for an additional 3,000 megawatts of storage. [GPI Reply Comments, 2/22/16, pg. 2.] If the Commission approves a higher ESP target, we suggest a four-part revised ESP structure that acknowledges natural divisions between scale and technology types: 1) community storage of all types (1 MW and smaller); 2) medium-scale storage of all types (1-20 MW); 3) large storage of all types MW); 4) bulk storage (50 MW and up for hydro and other large-scale storage technologies). [GPI Reply Comments, 2/22/16, pg. 2.]
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