look forward to additional dialog on this matter in the future rulemaking contemplated in this decision. Flexibility The fifth and final section of Evergreen’s review of the project selection process addressed issues regarding whether the administrators currently have sufficient flexibility to change projects. Currently, the administrators are permitted to add, modify or cancel a project by filing a Tier 3 Advice Letter with the CPUC. This issue was also included within the scope of this proceeding at the request of PG&E, which requested that the Commission consider whether to provide a more streamlined, expedited Tier 2 advice letter approval process for new projects initiated between EPIC plan approvals: As a modification to D.15-09-005, PG&E requests that the Commission re-assess the level of approval process required when proposing project additions to an approved portfolio. PG&E proposes the CPUC revise the requirements to a Tier 2, instead of Tier 3, advice letter, which will still allow adequate time for evaluation of a proposed project based on that project’s merits, while also making the approval process more nimble. This approach helps PG&E and the other IOUs stay current with new RD&D developments and propose projects that meet evolving customer needs and California’s aggressive energy policy goals. SCE joins PG&E in asserting that the current Tier 3 advice letter process for initiating new projects does not provide the utility administrators the flexibility needed to react to new technology, energy policy goals, Commission proceedings, and outside funding opportunities. Like PG&E, SCE recommends the Commission lower the threshold from a Tier 3 to a Tier 2 approval.
look forward to additional dialog on this matter in the future rulemaking contemplated in this decision. Flexibility The fifth and final section of Evergreen’s review of the project selection process addressed issues regarding whether the administrators currently have sufficient flexibility to change projects. Currently, the administrators are permitted to add, modify or cancel a project by filing a Tier 3 Advice Letter with the CPUC. This issue was also included within the scope of this proceeding at the request of PG&E, which requested that the Commission consider whether to provide a more streamlined, expedited Tier 2 advice letter approval process for new projects initiated between EPIC plan approvals: As a modification to D.15-09-005, PG&E requests that the Commission re-assess the level of approval process required when proposing project additions to an approved portfolio. PG&E proposes the CPUC revise the requirements to a Tier 2, instead of Tier 3, advice letter, which will still allow adequate time for evaluation of a proposed project based on that project’s merits, while also making the approval process more nimble. This approach helps PG&E and the other IOUs stay current with new RD&D developments and propose projects that meet evolving customer needs and California’s aggressive energy policy goals. SCE joins PG&E in asserting that the current Tier 3 advice letter process for initiating new projects does not provide the utility administrators the flexibility needed to react to new technology, energy policy goals, Commission proceedings, and outside funding opportunities. Like PG&E, SCE recommends the Commission lower the threshold from a Tier 3 to a Tier 2 approval.
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