credit from 30% to 10%. Utility allows us to avoid a number of scale solar has decreased in price other problematic issues that by 75% in less than a decade. A would be associated with reduction of only 20% in cost over implementing such a the next several years, a reasonable requirement now. The prospect assumption considering the historic of a large amount of departing solar cost decline trend, would fully CCA load in the next decade compensate for the reduced tax creates a conundrum for (POC Comment On renewable procurement, even in credit.” Proposed Reference System Plan the context of RPS, let alone And Related Commission Policy at new IRP requirements. The pp. 10-11.) IOUs have made substantial RPS investments and may not well demonstrates need to engage in a great deal “[Attachment A] the continued declining cost of of RPS procurement in the near solar and the $1/watt-dc price for term, especially while facing 2017 utility scale solar as the prospect of a large amount demonstrate in the following figure of departing load. found in their (POC Thus, the for testimony.” largest “need” Reply Comment On Proposed renewables will exist for the Reference System Plan And CCAs that have yet to be Related Commission Policy at launched, since they will then pp. 4-5.) face an immediate RPS obligation under the law. But POC raised the issue of early such entities not yet procurement forcing IOUs to load are not positioned to be overprocure due to CCA departing able to take advantage of procurement before the immediate federal tax credit load: “Also, resource is actually needed for opportunities by purchasing policy objectives is likely to electricity for customers that increase total resource costs, and they do not yet serve. even create stranded costs for IOUs Therefore, if we ordered due to reduced load to CCAs, immediate additional renewable energy efficiency, and procurement in this decision, customer storage capturing we would be forced, at least to (POC Reply some degree, to rely on IOUs to "excess" renewables.” Comment On Proposed Reference undertake procurement that System Plan And Related they may not need by 2030 to Commission Policy at p. 12.) serve their bundled load, and then devise a likely-unpopular
credit from 30% to 10%. Utility scale solar has decreased in price by 75% in less than a decade. A reduction of only 20% in cost over the next several years, a reasonable assumption considering the historic solar cost decline trend, would fully compensate for the reduced tax credit.” (POC Comment On Proposed Reference System Plan And Related Commission Policy at pp. 10-11.) “[Attachment A] well demonstrates the continued declining cost of solar and the $1/watt-dc price for 2017 utility scale solar as demonstrate in the following figure found in their testimony.” (POC Reply Comment On Proposed Reference System Plan And Related Commission Policy at pp. 4-5.) POC raised the issue of early procurement forcing IOUs to overprocure due to CCA departing load: “Also, procurement before the resource is actually needed for policy objectives is likely to increase total resource costs, and even create stranded costs for IOUs due to reduced load to CCAs, energy efficiency, and customer storage capturing "excess" renewables.” (POC Reply Comment On Proposed Reference System Plan And Related Commission Policy at p. 12.) allows us to avoid a number of other problematic issues that would be associated with implementing such a requirement now. The prospect of a large amount of departing CCA load in the next decade creates a conundrum for renewable procurement, even in the context of RPS, let alone new IRP requirements. The IOUs have made substantial RPS investments and may not need to engage in a great deal of RPS procurement in the near term, especially while facing the prospect of a large amount of departing load. Thus, the largest “need” for renewables will exist for the CCAs that have yet to be launched, since they will then face an immediate RPS obligation under the law. But such entities not yet load are not positioned to be able to take advantage of immediate federal tax credit opportunities by purchasing electricity for customers that they do not yet serve. Therefore, if we ordered immediate additional renewable procurement in this decision, we would be forced, at least to some degree, to rely on IOUs to undertake procurement that they may not need by 2030 to serve their bundled load, and then devise a likely-unpopular
231086612.docx