D.18-02-018, p.91 Our preference at this stage is to evaluate the individual LSE IRP filings later this year to determine the extent of the actual need for additional renewable procurement, with the benefit of the LSEs’ individual analysis. We expect some LSEs will have a near-term need for renewables and will propose to procure.” D.18-02-018, p. 152, 153 3. Transmission impact: the ALJ Ruling Verified “…as Early in the proceeding acknowledges, A&S document “This UCAN expressed acts as a bridge between the concern about previous LTPP process and the understanding the impact the successor IRP process.” But of several significant LTPP timing is also complicated by regulatory and legislative several significant regulatory and changes, including the legislative changes, e.g., the IRP process on transition of residential customers to default TOU rates, SB 350 California’s transmission infrastructure. While legislation that mandates increases transitioning from the in RPS from 33 to 50 percent and previous LTPP process to GHG emissions to 40 percent the successor IRP reduction by year 2030…However, process, UCAN since we know these changes cautioned the although speculative, are coming, Commission about UCAN is concerned about moving forward without understanding the impact on testing the impact on transmission capacity needed to infrastructure through bring solar and wind resources over sensitivity analyses. long distances to the load centers or Specifically, UCAN the impact of significant growth in advised that the BTM solar energy on the grid Commission should without at least testing these estimate the implications through sensitivity consequences of both we are uncertain about analysis…If making transmission the future in certain respects, we investments and not need to estimate the consequences of making transmission both 1) making transmission investments. investments and discovering the transmission investments were not needed or 2) not making the
D.18-02-018, p.91 Our preference at this stage is to evaluate the individual LSE IRP filings later this year to determine the extent of the actual need for additional renewable procurement, with the benefit of the LSEs’ individual analysis. We expect some LSEs will have a near-term need for renewables and will propose to procure.” D.18-02-018, p. 152, 153 3. Transmission impact: Early in the proceeding UCAN expressed concern about understanding the impact of several significant regulatory and legislative changes, including the IRP process on California’s transmission infrastructure. While transitioning from the previous LTPP process to the successor IRP process, UCAN cautioned the Commission about moving forward without testing the impact on infrastructure through sensitivity analyses. Specifically, UCAN advised that the Commission should estimate the consequences of both making transmission investments and not making transmission investments. “…as the ALJ Ruling acknowledges, “This A&S document acts as a bridge between the previous LTPP process and the successor IRP process.” But the LTPP timing is also complicated by several significant regulatory and legislative changes, e.g., the transition of residential customers to default TOU rates, SB 350 legislation that mandates increases in RPS from 33 to 50 percent and GHG emissions to 40 percent reduction by year 2030…However, since we know these changes although speculative, are coming, UCAN is concerned about understanding the impact on transmission capacity needed to bring solar and wind resources over long distances to the load centers or the impact of significant growth in BTM solar energy on the grid without at least testing these implications through sensitivity analysis…If we are uncertain about the future in certain respects, we need to estimate the consequences of both 1) making transmission investments and discovering the transmission investments were not needed or 2) not making the Verified
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