2. Flexibility for LSEs may find the marginal Verified IOU’s “Some in adoption of GHG cost of achieving the next unit of reducing generation: GHG reduction to be lower than UCAN supported the others. Those LSEs with lower concept that if statewide marginal cost of GHG reduction goals could be met, each could add more and those with individual LSEs should higher marginal cost of GHG not be forced to adopt reduction could add less GHG GHG reducing emissions-reducing generation, generation because it which could have the net result of could prove to be too meeting state-wide emission costly to reduction targets with a least-cost ratepayers…and that those with effect for LSE’s California’s ratepayers.” lower marginal costs of UCAN Comments on PD, p. 5, 6 achieving the next unit of January 17, 2018 GHG reduction could add more while those The main goal is to achieve the least with higher marginal cost resource plan while subject to costs could add less but certain statewide regulatory still reduce overall state constraints, such as the reduction of wide GHG emissions. GHG emissions. UCAN has previously expressed that LSEs differ in many respects, including While not addressing this historical efforts concerning GHG point directly, the emissions reduction as well as the Commission did not need for, and optimal timing of, new require the LSEs to resource additions. This flexibility procure more renewables issue is supported in the PD at this time, preferring to UCAN Reply Comments on PD, p. 5 wait until further evaluation of individual Each LSE will be required to plan LSE IRP filings to toward adherence to the reference determine any actual system portfolio, with specific need for additional justification given when its plan renewable procurement. deviates from the reference portfolio. When it comes to actual procurement, we expect that LSEs will choose the most appropriate and effective resources offered to them that meet their customers’ needs, when analyzing cost, reliability, and disadvantaged communities impacts, among other considerations.
2. Flexibility for IOU’s in adoption of GHG reducing generation: UCAN supported the concept that if statewide goals could be met, each individual LSEs should not be forced to adopt GHG reducing generation because it could prove to be too costly to ratepayers…and that those LSE’s with lower marginal costs of achieving the next unit of GHG reduction could add more while those with higher marginal costs could add less but still reduce overall state wide GHG emissions. While not addressing this point directly, the Commission did not require the LSEs to procure more renewables at this time, preferring to wait until further evaluation of individual LSE IRP filings to determine any actual need for additional renewable procurement. “Some LSEs may find the marginal cost of achieving the next unit of GHG reduction to be lower than others. Those LSEs with lower marginal cost of GHG reduction could add more and those with higher marginal cost of GHG reduction could add less GHG emissions-reducing generation, which could have the net result of meeting state-wide emission reduction targets with a least-cost effect for California’s ratepayers.” UCAN Comments on PD, p. 5, 6 January 17, 2018 The main goal is to achieve the least cost resource plan while subject to certain statewide regulatory constraints, such as the reduction of GHG emissions. UCAN has previously expressed that LSEs differ in many respects, including historical efforts concerning GHG emissions reduction as well as the need for, and optimal timing of, new resource additions. This flexibility issue is supported in the PD UCAN Reply Comments on PD, p. 5 Each LSE will be required to plan toward adherence to the reference system portfolio, with specific justification given when its plan deviates from the reference portfolio. When it comes to actual procurement, we expect that LSEs will choose the most appropriate and effective resources offered to them that meet their customers’ needs, when analyzing cost, reliability, and disadvantaged communities impacts, among other considerations. Verified
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