Decision at 54. beneficial areas.” opposed the portfolio “EDF recommendation because it does not contain enough DERs or accurately reflect their value to the system.” Decision at 67. 6. EDF expressed in comments parties commented on Verified “Numerous that the total resource cost the manner in which resource costs (TRC) test did not present an are treated in RESOLVE. Staff used adequate representation of a total resource cost metric, which costs and benefits. was favored by PG&E, SDG&E, NRG, ORA, and LSA. SEIA, POC, and EDF do not believe that the TRC approach is appropriate for BTM PV Decision and/or storage.” at 39. 7. EDF expressed in would prefer that the Verified “EDF comments that reliance on Commission emphasize curtailment was costly and development of DERs that match unnecessary, given the demand, rather than relying on potential of DERs to match curtailment Decision at strategies.” demand in a more 40. efficient way. 8. EDF stated in comments is concerned that the benefits Verified “EDF that the 30 million metric ton of DERs are not fully reflected in (MMT) GHG target was the analysis and thus the imminently achievable and Commission should be more urged the Commission to be aggressive than 42 MMT.” more ambitious. Decision at 47. 9. EDF stated in comments that other parties disagreed Verified “Numerous consideration of the impacts with the recommendations by staff, (positive or negative) on including AReM, CalCCA, EDF, disadvantaged communities Imperial County, National Grid, should be a more robust NRG, PG&E, SDG&E, and consideration in the staff EDF objected to the SoCalGas… proposal. staff recommendations because they do not go far enough to address the fact that disadvantaged communities suffer disproportionately from the impacts of poor air quality.” Decision at 53. 10. EDF urged the comments focused on the Verified “EDF’s Commission to consider the possibility of a regional market in
beneficial areas.” Decision at 54. “EDF opposed the portfolio recommendation because it does not contain enough DERs or accurately reflect their value to the system.” Decision at 67. 6. EDF expressed in comments that the total resource cost (TRC) test did not present an adequate representation of costs and benefits. “Numerous parties commented on the manner in which resource costs are treated in RESOLVE. Staff used a total resource cost metric, which was favored by PG&E, SDG&E, NRG, ORA, and LSA. SEIA, POC, and EDF do not believe that the TRC approach is appropriate for BTM PV and/or storage.” Decision at 39. Verified 7. EDF expressed in comments that reliance on curtailment was costly and unnecessary, given the potential of DERs to match demand in a more efficient way. “EDF would prefer that the Commission emphasize development of DERs that match demand, rather than relying on curtailment strategies.” Decision at 40. Verified 8. EDF stated in comments that the 30 million metric ton (MMT) GHG target was imminently achievable and urged the Commission to be more ambitious. “EDF is concerned that the benefits of DERs are not fully reflected in the analysis and thus the Commission should be more aggressive than 42 MMT.” Decision at 47. Verified 9. EDF stated in comments that consideration of the impacts (positive or negative) on disadvantaged communities should be a more robust consideration in the staff proposal. “Numerous other parties disagreed with the recommendations by staff, including AReM, CalCCA, EDF, Imperial County, National Grid, NRG, PG&E, SDG&E, and SoCalGas… EDF objected to the staff recommendations because they do not go far enough to address the fact that disadvantaged communities suffer disproportionately from the impacts of poor air quality.” Decision at 53. Verified 10. EDF urged the Commission to consider the “EDF’s comments focused on the possibility of a regional market in Verified
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