targets and indications (now MWs of capacity each should be law), that the RPS would rejected, and that SCE should procure a increase to 50 percent by 2030. smaller 360 MW facility in their place. Sierra Club argued that the Sierra Club, as addressed above, also value of the fossil fuel requests the Commission to reject resources SCE planned to (Decision p. 26.) Stanton.” procure would be worth argument is based on “Sierra Club’s significantly less under a 50% the fact that procurement SCE’s RPS scenario (only ½ way assumed future requirements at 33 through the contract life) and percent RPS, and did not study the that SCE should therefore sensitivity of the resource value for procure only its fossil fuel GFG at higher renewable levels. minimum. Decision 15-11-051 Therefore, according to Sierra Club, ultimately found it reasonable the economic benefit of a combined for SCE to rely on 33% RPS cycle was overstated in the SCE RFO given that was in place at the process and the economic value of in time of contracting. front of the meter Energy Storage was (Testimony of Robert Fagan on understated. It would make more sense, Behalf of Sierra Club; Sierra states Sierra Club, given the state’s Club Opening Br. 17-18) increasing interest in a higher requirement for renewables resources, to procure the minimum required GFG or (Decision pp. 26-27.) 1,000 MW.” of whether circumstances “Regardless have changed since the issuance of D.13-02-015 and D.14-03-004, and even if the political landscape is solidly looking toward 50 percent renewables, we find SCE acted reasonably in relying on a 33 percent scenario and contracting for the proposed amount of GFG.” (Decision pp. 28-29.) Duplication of Effort (§ 1801.3(f) and § 1802.5): CPUC Intervenor’s Assertion Discussion a. Was the Office of Ratepayer Advocates (ORA) a party to Yes Verified the proceeding? Yes Verified b. Were there other parties to the proceeding with positions similar to yours? c. If so, provide name of other parties: ORA (issues 1 and 2), Powers Verified Engineering (issue #3)
targets and indications (now law), that the RPS would increase to 50 percent by 2030. Sierra Club argued that the value of the fossil fuel resources SCE planned to procure would be worth significantly less under a 50% RPS scenario (only ½ way through the contract life) and that SCE should therefore procure only its fossil fuel minimum. Decision 15-11-051 ultimately found it reasonable for SCE to rely on 33% RPS given that was in place at the time of contracting. (Testimony of Robert Fagan on Behalf of Sierra Club; Sierra Club Opening Br. 17-18) MWs of capacity each should be rejected, and that SCE should procure a smaller 360 MW facility in their place. Sierra Club, as addressed above, also requests the Commission to reject Stanton.” (Decision p. 26.) “Sierra Club’s argument is based on the fact that SCE’s procurement assumed future requirements at 33 percent RPS, and did not study the sensitivity of the resource value for GFG at higher renewable levels. Therefore, according to Sierra Club, the economic benefit of a combined cycle was overstated in the SCE RFO process and the economic value of in front of the meter Energy Storage was understated. It would make more sense, states Sierra Club, given the state’s increasing interest in a higher requirement for renewables resources, to procure the minimum required GFG or 1,000 MW.” (Decision pp. 26-27.) “Regardless of whether circumstances have changed since the issuance of D.13-02-015 and D.14-03-004, and even if the political landscape is solidly looking toward 50 percent renewables, we find SCE acted reasonably in relying on a 33 percent scenario and contracting for the proposed amount of GFG.” (Decision pp. 28-29.) Duplication of Effort (§ 1801.3(f) and § 1802.5): Intervenor’s Assertion CPUC Discussion a. Was the Office of Ratepayer Advocates (ORA) a party to the proceeding? Yes Verified b. Were there other parties to the proceeding with positions similar to yours? Yes Verified c. If so, provide name of other parties: ORA (issues 1 and 2), Powers Engineering (issue #3) Verified
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