Decision D.18-02-018 to note that we “UCAN would like sets requirements for the generally support the process LSEs to file IRPs on or suggested by the PD and we support before June 1, 2018. its attempt to provide load serving These requirements entities (LSEs) sufficient flexibility include several of the to procure least-cost resources that concepts offered by provide the greatest value to UCAN throughout the ratepayers.” proceeding, including flexibility for LSE’s UCAN Comments on PD, p. 3 when developing individual IRPs and in the adoption of GHG reducing generation, as well as consideration of transmission impacts. 1. Flexibility for ideal LSE IRP should reflect Verified IOU’s “The when developing the least cost energy resource individual UCAN additions in which the LSE controls IRP’s: supported flexibility for the timing and type of resources each LSE to develop added each year to meet the State’s their own individual IRP RPS and GHG mandated goals. that could meet the Each LSE, developing its least cost required targets rather IRP, should have the flexibility to meet the required targets and each than “top down” mandated portfolios LSE should be able to contribute to because this would allow statewide goals as efficiently as each LSE to contribute to possible.” statewide goals as UCAN Comments on CPUC Staff efficiently as possible. Proposal for Implementing IRP, p. 8 June 28, 2017 Ultimately, the LSEs may be able to “Individual Commission adopted this identify optimal portfolios to serve concept and allowed the their load that differ from the mix individual LSEs identified in the Commission flexibility to propose reference system portfolio. LSEs alternate portfolios to the should be given flexibility to propose reference system alternate portfolios to meet their portfolio in addition to customer needs, in addition to conforming portfolios. conforming portfolios, while justifying any deviations from the reference portfolio.” D.18-02-018, Findings of Fact #9, p. 161
Decision D.18-02-018 sets requirements for the LSEs to file IRPs on or before June 1, 2018. These requirements include several of the concepts offered by UCAN throughout the proceeding, including flexibility for LSE’s when developing individual IRPs and in the adoption of GHG reducing generation, as well as consideration of transmission impacts. “UCAN would like to note that we generally support the process suggested by the PD and we support its attempt to provide load serving entities (LSEs) sufficient flexibility to procure least-cost resources that provide the greatest value to ratepayers.” UCAN Comments on PD, p. 3 1. Flexibility for IOU’s when developing individual IRP’s: UCAN supported flexibility for each LSE to develop their own individual IRP that could meet the required targets rather than “top down” mandated portfolios because this would allow each LSE to contribute to statewide goals as efficiently as possible. Ultimately, the Commission adopted this concept and allowed the individual LSEs flexibility to propose alternate portfolios to the reference system portfolio in addition to conforming portfolios. “The ideal LSE IRP should reflect the least cost energy resource additions in which the LSE controls the timing and type of resources added each year to meet the State’s RPS and GHG mandated goals. Each LSE, developing its least cost IRP, should have the flexibility to meet the required targets and each LSE should be able to contribute to statewide goals as efficiently as possible.” UCAN Comments on CPUC Staff Proposal for Implementing IRP, p. 8 June 28, 2017 “Individual LSEs may be able to identify optimal portfolios to serve their load that differ from the mix identified in the Commission reference system portfolio. LSEs should be given flexibility to propose alternate portfolios to meet their customer needs, in addition to conforming portfolios, while justifying any deviations from the reference portfolio.” D.18-02-018, Findings of Fact #9, p. 161 Verified
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