advocacy that these revisions were worthy of further study. 4. TURN contributed to the Comments of TURN Regarding Study Verified record on the development of a Plans for Durable Flexible Capacity durable (as opposed to interim) Program Topics, 9/23/16, pp. 1-3. flexible capacity requirement, Comments of TURN on Track 2, but ultimately, along with other Question 1 (“Reliability Needs Problem parties, recommended that the Statement”), 2/5/16, pp. 1-2. Commission defer Comments of TURN on Preliminary implementation of such a Phase 3 Proposals, 1/13/17, p. 7. requirement. The Commission decided to defer this issue, quoting TURN’s comments D.17-06-027, p. 17. (among others). 5. TURN, among other parties, Comments of TURN on Preliminary Verified opposed adoption of a Phase 3 Proposals, 1/13/17, pp. 5-6. Year RA requirement at this Comments of TURN on Forward time and opposed IEP’s Capacity Procurement Report and proposal for the Commission to Related Proposals, 2/16/17, pp. 1-3. decide a matter of policy” “as Comments of TURN on Final Phase 3 the amount of RA capacity Proposals, 3/10/17, pp. 12-13. jurisdictional LSEs should procure 3 and 5 years forward. TURN supported IEP’s D.17-06-027, pp. 17-18. proposal for an annual report of forward capacity procurement in the interest of market transparency. The Commission did not adopt a multi-year requirement and rejected IEP’s proposal to address the substantive issues relating to such a requirement at this time. While the Commission did not adopt IEP’s forward capacity reporting requirement, it noted the Energy Division’s current efforts in this regard and encouraged continued monitoring and reporting. 6. TURN opposed parties’ Reply Comments of TURN on the PD, Verified recommendations to modify 6/19/17, pp. 1-2. the PD to adopt more costly ELCC approaches. Consistent
advocacy that these revisions were worthy of further study. 4. TURN contributed to the record on the development of a durable (as opposed to interim) flexible capacity requirement, but ultimately, along with other parties, recommended that the Commission defer implementation of such a requirement. The Commission decided to defer this issue, quoting TURN’s comments (among others). Comments of TURN Regarding Study Plans for Durable Flexible Capacity Program Topics, 9/23/16, pp. 1-3. Comments of TURN on Track 2, Question 1 (“Reliability Needs Problem Statement”), 2/5/16, pp. 1-2. Comments of TURN on Preliminary Phase 3 Proposals, 1/13/17, p. 7. D.17-06-027, p. 17. Verified 5. TURN, among other parties, opposed adoption of a RA requirement at this time and opposed IEP’s proposal for the Commission to decide “as a matter of policy” the amount of RA capacity jurisdictional LSEs should procure 3 and 5 years forward. TURN supported IEP’s proposal for an annual report of forward capacity procurement in the interest of market transparency. The Commission did not adopt a multi-year requirement and rejected IEP’s proposal to address the substantive issues relating to such a requirement at this time. While the Commission did not adopt IEP’s forward capacity reporting requirement, it noted the Energy Division’s current efforts in this regard and encouraged continued monitoring and reporting. Comments of TURN on Preliminary Phase 3 Proposals, 1/13/17, pp. 5-6. Comments of TURN on Forward Capacity Procurement Report and Related Proposals, 2/16/17, pp. 1-3. Comments of TURN on Final Phase 3 Proposals, 3/10/17, pp. 12-13. D.17-06-027, pp. 17-18. Verified 6. TURN opposed parties’ recommendations to modify the PD to adopt more costly ELCC approaches. Consistent Reply Comments of TURN on the PD, 6/19/17, pp. 1-2. Verified Year
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