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Advocacy at the California Public Utilities Commission (CPUC)
CEERT’s Regulatory Counsel Sara Steck Myers and Associate Regulatory Attorney Megan Myers act as advocates and intervenors before the CPUC and other regulatory agencies to ensure fairly pricing for clean power, improve renewable energy procurement planning, and strengthen implementation of the state’s Renewable Portfolio Standard (RPS). CEERT is helping lead the fight for innovative policies that reflect the true value, costs, and benefits of clean, renewable energy.
CPUC Investigations of PG&E (i.e., Plan of Reorganization) and SoCalGas/Sempra
CPUC Investigation of Pacific Gas & Electric’s (PG&E’s) Governance and Safety Culture (I.15-08-019)
This investigation, instituted in 2015, was brought to life again due to PG&E’s misconduct and mismanagement on wildfires and gas service, with a process started in Summer 2019 to consider proposals to improve PG&E’s safety culture. CEERT and other parties offered or supported changes in PG&E’s corporate structure that would advance reductions in greenhouse-gas (GHG) emissions. Other proposals have included municipalization of PG&E and limiting PG&E to a “wires-only” (transmission) company.
From Fall 2019 to the present, this proceeding has largely been on hold as the CPUC focused on a review of PG&E’s plan of reorganization to exit bankruptcy in I.19-09-016. CEERT has participated in I.19-09-016 to ensure that any approval of a PG&E reorganization plan will not limit or defer the CPUC’s continuing consideration of other changes to PG&E to improve its safety culture and operation in I.15-08-019.
On July 15, Administrative Law Judge (ALJ) Allen issued a Ruling on Case Status, which states that absent a compelling reason, the CPUC will close I.19-09-016 in the near future. The Ruling also requests party input on what next steps to take in the Safety proceeding (I.15-08-019). Comments were submitted on August 4 and Reply Comments on August 13.
On August 4, CEERT submitted Comments on the Case Status of I.15-08-019. We argued that I.15-08-019 remains a critical proceeding and, more important, is the home to a developed record of multiple proposals for changes to PG&E’s culture and governance that go far beyond the limited scope of I.19-09-016 and deserve careful consideration in moving PG&E forward to becoming a “responsible utility.”
On September 4, ALJ Allen issued a Ruling Updating Case Status, determining that I.15-08-019 will remain open as a vehicle to monitor PG&E’s progress in improving its safety culture, and to address any relevant issues that arise, with NorthStar Consulting Group continuing in a monitoring role.
CPUC’s Investigation of PG&E Maintenance, Operations and Practices (I.19-06-015)
On May 7, the Commission issued D.20-05-019, approving a Settlement Agreement (SA) with modifications, closing the proceeding, pending approval of the SA by the Bankruptcy Court, and imposing penalties on PG&E totaling $2.137 billion, including a $200 million fine that would be permanently suspended.
On June 8, Thomas Del Monte submitted an Application for Rehearing and Wild Tree Foundation also submitted an Application for Rehearing. Thomas Del Monte requests that the $200 million fine be reinstated as payable in full and that the Tubbs Fire be removed from the scope of the Settlement and the Order Instituting Investigation be reopened and assigned a new Assigned Commissioner and ALJ to fully investigate PG&E legal and regulatory violations related to the Tubbs Fire. Wild Tree Foundation urges the Commission to recognize that the modified settlement approved in the Decision is contrary to the law, not in the public interest, and not reasonable in light of the record, and was approved in violation of due process and the Public Utilities Code.
PG&E’s Reorganization Application (A.20-06-011)
On June 30, PG&E submitted an Application for Approval of Regionalization Proposal. On August 5, CEERT submitted a Protest to the Application, objecting to limitations placed by PG&E on the scope and objectives of its Regionalization Proposal. We urged the CPUC to ensure consideration in this Application of other organizational changes to P&GE, other than as proposed, that will improve the safety and efficiency of PG&E’s operations in the transmission and distribution of electricity to its customers and achieve climate change goals. The CPUC held a Prehearing Conference on August 20, but a Scoping Memo has not yet been issued.
CPUC’s Investigation of SoCalGas/Sempra (I.19-06-014)
On June 27, 2019, the CPUC issued I.19-06-014, an Order Instituting Investigation to determine whether SoCalGas’s and Sempra’s organizational culture and governance prioritize safety. On July 27, 2020, Commissioner Randolph and ALJ Allen issued a Ruling on Process and Schedule for Proceeding. The initial stage of this proceeding will evaluate Sempra’s organizational culture, governance, policies, practices, and accountability metrics and their effects on SoCalGas. During this initial phase, the CPUC’s consultant may consider the Blade Report and other information on the Aliso Canyon gas leak. The Assigned Commissioner and ALJ will set a Prehearing Conference or equivalent to determine next steps after the CPUC receives the consultant’s report. There has not been any activity in this proceeding since the issuance of the Ruling.
CPUC Energy Planning and Procurement and Resource Adequacy
Senate Bill (SB) 100
On September 2, the CEC held an SB 100 Draft Results Workshop. V. John White participated in public comment, flagging the need to ground-truth the modeling assumptions and recommending that the Joint Agency Report SB 100 mandates be executed more frequently than every four years, given the urgency of the clean energy transition. On September 15, CEERT filed written comments in the SB 100 Docket that expanded on John’s remarks at the workshop, highlighting the urgency of evolving California’s RA structure and the importance of focusing on an orderly and just transition away from gas. As the CEC SB 100 Webpage indicates, there are no upcoming events.
Integrated Resource Planning (IRP)(R16-02-007 and R20-05-003) and Procurement-Related Activities
There has been recent activity in both IRP proceedings (R.16-02-007 and R.20-05-003).
R.16-02-007/D.19-11-016 (System Reliability Procurement 2021-23) (Legal Challenges and RFOs)
On November 7, 2019, the CPUC issued D.19-11-016 Requiring Electric System Reliability Procurement for 2021-2023. In December, multiple Rehearing Requests and Petitions for Modification were filed, challenging or seeking changes to the decision, especially its gas procurement authorizations.
On July 21, the CPUC issued D.20-07-009 Denying California Energy Storage Alliance (CESA) Petition for Modification (PFM) of D.19-11-016. CESA had sought to require that any contracts entered into by the investor-owned utilities (IOUs) for the online date of August 1, 2021 be processed by the CPUC with Tier 2 advice letters, instead of Tier 3 advice letters as required by D.19-11-016. Though the PFM is denied, the Proposed Decision commits to processing the IOU filings for 2021 as quickly as possible, including utilizing all appropriate means of expediting Tier 3 advice letters.
On September 28, the CPUC issued D.20-09-026, which grants California Community Choice Association’s (CalCCA’s) Petition for Modification (PFM) of D.19-11-016. To satisfy the capacity procurement requirements in D.19-11-016, CalCCA sought to have the qualifying capacity (QC) methodology for hybrid projects updated to the CPUC’s most recent definitions adopted in R.19-11-009 (Resource Adequacy); this decision affirms those updates. CalCCA also requested that the CPUC modify the cost allocation principles articulated in D.19-11-016 to require that load-serving entities be billed for capacity procured on behalf of their customers, rather than having the customers themselves billed through a non-bypassable surcharge. This decision allows for that possibility, but does not require it; record development and final decision-making on this topic is ongoing in the new IRP R.20-05-003, which will address the finer points of cost allocation for capacity procured to comply with D.19-11-016. The Decision addresses the last remaining substantive request in R.16-02-007 and closes the proceeding.
R.20-05-003 (New IRP OIR)
The CPUC instituted new IRP Rulemaking R.20-05-003 at its May 7 Business Meeting. On June 15, CEERT submitted Opening Comments, arguing that the CAISO must analyze all emission targets thoroughly to set California on track to meet its climate goals. We recommended that the Commission facilitate closer coordination between the RA and IRP proceedings, and that Energy Division Staff evaluate innovative solutions from other entities beyond the traditional network of agencies. CEERT stated that the CPUC should hold an En Banc hearing to allow an exchange of ideas before undertaking the next IRP cycle, and that the Commission must acknowledge the context surrounding the opening of R.20-05-003.
On July 6, CEERT submitted Reply Comments, urging that IRP modeling be improved to ensure the state is on track to meet its climate goals, and that the CPUC prioritize a just, orderly transition away from fossil fuel generation in this IRP cycle. We pointed out that alignment between the IRP and the CAISO Transmission Planning Process (TPP), and between the IRP and RA proceedings, are vital to successful decarbonization, and noted again that the CPUC should hold an En Banc hearing to evaluate all options.
R.20-05-003 – Backstop Procurement Ruling
On June 5, ALJ Fitch issued a Ruling Seeking Comments on cost allocation policy and mechanisms for procurement conducted by one IRP load-serving entity (LSE) on behalf of another; and a backstop procurement mechanism in the event that a non-utility LSE with a procurement obligation fails to secure the required resources. Opening Comments were submitted on July 22 and Reply Comments on August 7.
R.20-05-003 – Prehearing Conference
On June 15, ALJ Fitch issued a Ruling scheduling a July 14 Prehearing Conference, at which the ALJ identified two paths forward for this proceeding. The first would be for the CPUC to analyze LSEs’ individual IRPs in a robust way. The second would be for the CPUC to conduct better long-term locational planning analysis, and then give IRP planning and procurement direction to LSEs. The second option would include: (1) analysis of specific individual gas plant retirements, (2) specific analysis of long-term local reliability needs in local capacity areas, (3) replacement power for Diablo Canyon, (4) designation of the need to procure specific, or at least specific amounts of, long-duration storage and (5) designation of the need for out-of-state wind and/or offshore wind in particular geographic areas to support transmission development to access the resources.
At the Prehearing Conference, CEERT supported Path Two, and reemphasized the need for En Banc hearings. The Transcript was issued on July 21, and on July 24 we submitted Reply Comments on the June 15 Ruling, recommending that the CPUC adopt the three-year time frame identified in the proposed schedule if it leads to the CPUC conducting better long-term locational planning analysis. We also continued our advocacy for interagency coordination on the IRP process. Attachment A to the Reply Comments was a Letter and Recommendations from the Alliance for a Clean Economy, which includes CEERT, that was sent to the Governor on July 16.
R.20-05-003: Scoping Memo and Ruling
On September 24, Assigned Commissioner Randolph issued a Scoping Memo and Ruling in R.20-05-003. The issues to be resolved include: general IRP oversight issues, procurement track, adoption of a Preferred System Portfolio (PSP), recommendations for the CAISO’s TPP, and development of the next Reference System Portfolio (RSP). The schedule is:
- October 2020: Proposed Decision addressing backstop procurement and cost allocation
- November 2020: Commission Decision on backstop procurement and cost allocation
- January 2021: Ruling circulating Diablo Canyon replacement power analysis and gap analysis, and proposing procurement strategy for any additional needed power, along with proposed broader framework for IRP procurement
- January 2021: Possible workshop on results of staff analysis on Diablo Canyon procurement
- February 2021: Comments on Diablo Canyon analysis
- March 2021: Reply Comments on Diablo Canyon analysis
- April 2021: Proposed Decision on Diablo Canyon analysis
- May 2021: Commission Decision on Diablo Canyon analysis
- May 2021: LSEs file annual IRP data
- Second Quarter 2021: Ruling seeking additional comments on longer-term elements of a procurement framework, including plans for long-lead-time resources
- Third Quarter 2021: Comments on longer-term elements of procurement framework
- October 2020: Ruling seeking comments on proposed portfolio(s) and busbar mapping methodologies for 2021-2022 TPP
- November 2020: Comments on proposed portfolio(s) for 2021-2022 TPP
- November 2020: Reply Comments on proposed portfolio(s) for 2021-2022 TPP
- January 2021: Proposed Decision recommending portfolio(s) for 2021-2022 TPP
- February 2021: Commission adoption of decision recommending portfolio for 2021-2022 TPP
- Fall 2020: Modeling Advisory Group meeting examining GHG emissions benchmarking and modeling differences
- Fall 2020: Ruling on resubmittals of information for deficient LSE IRPs, if needed
- First Quarter 2021: Workshop on reconciled portfolio aggregation of all LSE IRPs
- First Quarter 2021: Production cost modeling of portfolio aggregations
- Second Quarter 2021: Workshop on options for PSP and any associated procurement required, as well as 2022-2023 TPP portfolio
- Second Quarter 2021: Ruling proposing PSP, procurement and 2022-2023 TPP portfolio
- Third Quarter 2021: Proposed Decision adopting PSP, procurement and 2022-2023 TPP portfolio
- Fourth Quarter: Commission Decision adopting PSP, procurement, and 2022-2023 TPP portfolio
Resource Adequacy (RA) (R.17-09-020 and R.19-11-009)
Central Procurement Decision
On June 17, the Commission issued D.20-06-002 in R.17-09-020, adopting implementation details for the central procurement of multiyear local RA to begin for the 2023 compliance year in the PG&E and Southern California Edison (SCE) distribution service areas, including identifying PG&E and SCE as the central procurement entities for their respective areas and adopting a “hybrid” central procurement framework. The decision declines to adopt a central procurement framework for the San Diego Gas & Electric (SDG&E) distribution service area at this time. CEERT believes this decision is deeply flawed, and will stifle innovation in the design of new clean resources to allow the retirement of existing gas generation.
On June 25, all five Commissioners voted to adopt D.20-06-028 on Resource Adequacy Requirements. The Decision addresses the issues scoped for limited rehearing in D.20-03-016 and the issues scoped as Track 1 in the Scoping Memo of R.19-11-009; it also adopts revisions to the RA import rules based on Energy Division’s proposal, with modifications. The Commission will consider the CAISO and Powerex Corp.’s proposal in a subsequent RA proceeding after further development in the CAISO’s processes. The decision completes the limited rehearing of D.19-10-021, and the stay of that decision is no longer in effect. The net effect of this decision will be to raise the cost and reduce the volume of imports, in the name of supposedly ensuring certainty of delivery on peak days.
Decision Denying Petitions for Modification
On September 16, the CPUC issued D.20-09-003 which denies the following Petitions for Modification as moot: PG&E’s PFM of D.19-02-022, CalCCA’s PFM of D.19-06-026, and the PFM of CEERT, Enel X, CESA and AWEA-CA (the Joint Parties) of D.20-01-044. PG&E’s PFM is moot and denied because the CPUC addressed reaggregation of the PG&E Other Local Capacity Area and adopted PG&E’s proposed compliance mechanism in D.20-06-031. CalCCA’s PFM is moot and denied because the CPUC addressed CalCCA’s proposal for system and flexible RA waivers in D.20-06-031 and declined to adopt the proposal. The Joint Parties’ PFM is moot and denied because the CPUC reconsidered the issue of the appropriate qualifying capacity (QC) methodology for hybrid resources in D.20-06-031 and adopted a definition of hybrid and co-located resources. CEERT does not believe this new QC methodology adequately compensates hybrid resources and has filed a proposal to correct this issue in next year’s RA proceeding (see below).
Annual RA Decision
On May 22 in R.19-11-009, the Commission issued a Proposed Decision Adopting Local Capacity Obligations for 2021-2023, Adopting Flexible Capacity Obligations for 2021 and Refining the Resource Adequacy Program. On June 11, CEERT submitted Opening Comments, arguing that the PD must reexamine RA from the ground up. We noted that every one of the “program enhancements” in the PD operates to restrict the supply and raise the price of non-fossil capacity resources in the name of “conservative assumptions” to avoid “speculative supply” or “potential non-performance,” and that the PD declines to even mention the ongoing need to develop RA methodologies and counting rules for behind-the-meter (BTM) aggregations of preferred resources.
On June 16, CEERT submitted Reply Comments, arguing that the PD again defers consideration of protocols for non-fossil alternatives such as BTM resources, continues to ignore targeted energy efficiency, saddles demand response (DR) with expensive, inflexible measurement and verification protocols, and makes “permanent” rules meant to be interim pending further development in Track 3 or with the benefit of commercial experience with the current open solicitation, such as the maximum cumulative capacity (MCC) buckets proposal or the hybrid counting rules proposal.
Between June 12 and June 18, representatives of CEERT met with Advisors for all five Commissioners. We expressed our disappointment that this PD declined to reexamine the RA program from the ground up and continued to lock in fossil fuel, making it more difficult to back out of gas contracts instead of working toward retiring once-through cooling plants. We made note of a growing consensus that the RA program is getting worse, not better, and needs to fundamentally change, particularly for BTM resources. For example, the MCC bucket proposal locks in the current resource mix by limiting the amount of resources that can be purchased for RA and mandating that the majority of these resources come from gas. CEERT stated that there is still a lot of work to do, and emphasized that the Scoping Memo for Track 3 of this proceeding is going to be a critical document.
On June 30, the CPUC issued D.20-06-031, which refines the RA program and adopts local capacity obligations for 2021-2023 and flexible capacity obligations for 2021 applicable to CPUC-jurisdictional LSEs.
Amended Track 3 Scoping Memo
On July 7, in R.19-11-009 (RA), Assigned Commissioner Randolph issued an Amended Track 3.A and 3.B Scoping Memo and Ruling that designates the following issues as being in Track 3.A or 3.B:
Track 3.A Issues
- Evaluation of the CAISO’s updated local capacity requirement (LCR) reliability criteria.
- Evaluation of an LCR reduction compensation mechanism.
- Consideration of the Central Procurement Entity’s competitive neutrality rules.
- Joint Agency Workshop on establishing net qualifying capacity (NQC) values for behind-the-meter hybrid storage/solar resources with the goal of counting these resources in the RA program.
- Other time-sensitive issues identified by Energy Division or other parties.
Track 3.B Issues
- Examination of broader RA capacity structure to address energy attributes and hourly capacity requirements, given the increasing penetration of use-limited resources, greater reliance on preferred resources, rolling off a significant amount of long-term tolling contracts held by utilities, and material increases in energy and capacity prices experienced in California over the past years.
- Other structural changes or refinements to the RA program identified during Track 1 or Track 2.
- Other time-sensitive issues identified by Energy Division or by parties.
Schedule for Track 3.A
- September 1, 2020: Working Group Reports and Proposals due
- September 11, 2020: Comments on Joint Agency Workshop, Working Group Reports and Proposals due
- September 18, 2020: Reply Comments on Joint Agency Workshop, Working Group Reports and Proposals due
- November 2020: Joint Agency Workshop on NQC values for hybrid BTM storage/solar resources
- Q4 2020: Proposed Decision on Track 3.A
Schedule for Track 3.B
- August 7, 2020: Proposals and Comments on Process due
- August-September, 2020: Potential Working Group meetings
- Late September/Early October 2020: Workshop(s) on Proposals
- October 15, 2020: Final Proposals due
- November 6, 2020: Comments on Workshop(s) and Proposals due
- November 20, 2020: Reply Comments on Workshop(s) and Proposals due
- Q1 2021: Proposed Decision on Track 3.B
A July 30 Workshop discussed 2021 RA templates and guides, and an LCR Working Group Meeting was held on August 13.
Track 3.A Proposals
On September 1, CEERT joined Enel X, CESA, Sunrun, and Tesla (the Joint Parties) to submit a Resource Adequacy Track 3.A Proposal. The Joint Parties argue that the scope of the Joint Agency Workshop and follow-up activities should consider not only solar-plus-storage but be expanded to include standalone storage and other clean distributed energy resources (DERs) that can export energy. Many of the cross-cutting issues should be addressed in an umbrella proceeding focused on multiple-use applications. The parties contend that different pathways should be developed and supported to enable DERs to have supply-side RA value or to get load-modification credit.
Track 3.B Proposals
On August 7, CEERT submitted our Track 3.B Proposal. We proposed that the Net Qualifying Capacity (NQC) value for RA purposes (and the Net Qualifying Energy if required by modifications to the RA structure based on other Track 3.B Proposals) be calculated on a project-specific basis at the time CAISO conducts Interconnection Studies, when all relevant variables for each project are known and individual project performance metrics are established for the CAISO Generator Master File. The QC calculations would use standard CPUC-developed and -authorized models and protocols, granular CEC forecasts of loads and load shapes, and the “and” methodology that sums the individual capacity contributions of the individual generating and storage components of the hybrid while taking account of any charging restrictions or point of interconnection constraints that could limit the NQC of the combined resources below the algebraic sum of the component QCs.
On September 22, CEERT met with Ed Randolph and RA Staff to discuss new data from a FERC Technical Conference, the Joint IOU study of the effective load-carrying capability (ELCC) of solar + storage for the RPS proceeding, and a new paper by E3 that supports CEERT’s proposal.
Joint Agency Workshop
In R.19-11-009, CEERT requested a Joint Agency Workshop of the CPUC, CAISO and CEC. On August 17, the CPUC noticed such a Joint CPUC/CAISO/CEC Workshop, scheduled for October 6 then postponed again until November, that will consider the potential of providing RA credit to hybrid storage/solar behind-the-meter (BTM) resources. It is clear that the CPUC does not consider this issue a priority, in spite of the obvious need for near-term system capacity and the fact that BTM resources made significant on-peak energy and capacity available to the system pro bono during the summer heat waves.
Amended Track 3.B Schedule
On September 23, ALJ Chiv issued a Ruling Modifying Track 3.B Schedule in R.19-11-009, as follows:
- November 2020: Workshop on draft Track 3.B proposals submitted August 7
- December 18, 2020: Revised Track 3.B proposals due
- January 15, 2021: Comments on Revised Track 3.B proposals due
- February 2021: Workshop on Revised Track 3.B proposals
- March 9, 2021: Second Revised Track 3.B proposals and comments on additional process due
- May 2021: Proposed Decision on Track 3.B and Track 4
- June 2021: Final Decision on Track 3.B and Track 4
Renewable Portfolio Standard (RPS) Program (R.18-07-003 (Current) & R.15-02-020 (Predecessor))
Renewable Market Adjusting Tariff (ReMAT)
On June 26, Assigned Commissioner Rechtschaffen and ALJ Lakhanpal issued a Ruling seeking comments from parties on proposed modifications to the Renewable Market Adjusting Tariff (ReMAT) program so that procurement under the program might resume promptly. The staff proposal would replace ReMAT’s adjusting pricing mechanism, eliminate the bimonthly program periods and program period caps, and use administratively determined prices by product category with a time-of-delivery adjustment. These proposed changes are necessary to bring the ReMAT program into compliance with an order from the federal district court. Comments were submitted on July 21 and Reply Comments on July 28.
On August 21, ALJ Lakhanpal issued a Proposed Decision modifying aspects of the ReMAT Program to bring it into compliance with the Public Utility Regulatory Policies Act of 1978 (PURPA) and § 399.20 of the Public Utilities Code. The PD adopts an electricity pricing methodology to calculate a fixed rate available to qualifying renewable generators that is based on a weighted average of the utilities’ recent executed long-term RPS contracts, which include time-of-delivery adjustment periods and factors. The ReMAT Program is modified to eliminate caps on procurement during bimonthly program periods and instead authorize procurement at the authorized rate on a first-come, first-served basis until each electric utility fulfills its proportionate share of procurement under § 399.20, along with additional changes. These modifications do not affect ReMAT contracts that have already been executed.
The CPUC is resuming the ReMAT Program, which has been suspended since December 2017. Federal courts have since clarified the requirements for the CPUC’s implementation of PURPA, and FERC issued new rules on state implementation, which will become effective 120 days from publication in the Federal Register. The PD does not resolve outstanding petitions for modification to the Program, and this proceeding will consider further changes in light of the petitions, as data on the newly revised Program’s performance and on other RPS procurement becomes available. Comments were due on September 10 and Reply Comments on September 15.
Bioenergy Market Adjusting Tariff (BioMAT)
On September 1 the CPUC issued D.20-08-043, a Decision Revising the Bioenergy Market Adjusting Tariff (BioMAT) Program that adopts these changes to program rules, contract terms and processes:
- The BioMAT program end date is extended to December 31, 2025.
- BioMAT procurement costs shall be allocated through a non-bypassable charge to all customers in each IOU’s service territory.
- Eligible BioMAT Category 2 – Other Agriculture projects must utilize the waste, residue, or by-products of growing crops, raising livestock, or growing horticultural products consistent with activities described as “crop production” and “animal production.”
- Projects utilizing directed biogas must submit their annual Common Carrier Pipeline report for the CEC to the Buyer as part of their Annual Fuel Attestation.
- A project’s Guaranteed Commercial Operation Date is 36 months from the contract execution date with the possibility of a 6-month extension.
- 140% of contracted energy must be delivered over two consecutive years for the first two years, and 180% of contracted energy must be delivered every two years for the remaining years.
- A project pays a forecasting penalty if it delivers +/- 3% of the contract capacity in any hour of any month, except for the first year when the penalty is waived.
- Projects may utilize non-BioMAT fuel that complies with the RPS Guidelines to supply the station service load.
- Telemetry requirements are set through the interconnection process.
- Projects must be metered through a CAISO revenue meter on the high-or-low voltage side of a Project’s final step-up transformer.
- A technical working group will be established to develop a project-specific lifecycle GHG model to quantify program emissions impacts.
- New deadlines are set for the IOUs to review applications and execute contracts.
- All applicants must attest at the start of each program period that they meet program eligibility criteria and face a penalty if they fail to report a change in their eligibility status.
Ruling Requesting Comments on the Energy Division Staff Proposal on IRP and RPS Integration
On September 18, ALJ Atamturk issued a Ruling Requesting Comments on the Energy Division’s “Staff Proposal for Alignment and Integration of RPS Procurement Planning and Integrated Resource Planning.” Comments were due on October 9 and Reply Comments on October 20.
Decision on New Community Choice Aggregators’ 2019 RPS Procurement Plans, PacifiCorp’s On-Year Supplement, and EnerCal’s Request for Waiver
On September 24, the Commission voted to adopt the Revised Proposed Decision on New Community Choice Aggregators’ 2019 RPS Procurement Plans, PacifiCorp’s On-Year Supplement, and EnerCal’s Request for Waiver. (Final Decision D.20-09-022 has not yet been issued). The PD deems as final and accepts the 2019 RPS Procurement Plans submitted by four new Community Choice Aggregators (CCAs) but cautions the CCAs that more detail is required in their future RPS Plans. The four affected CCAs are Butte Choice Energy Authority; Clean Energy Alliance; the City of Santa Barbara; and San Diego Community Power. Each of these CCAs is anticipated to start providing electricity to customers in 2021. The decision also deems as final and accepts PacifiCorp’s on-year supplement to its 2019 IRP, and grants EnerCal’s request for a waiver from filing RPS Plans until such time as it serves retail load.
Oakland Clean Energy Initiative (OCEI) (A.20-04-013)
On April 15, PG&E filed A.20-04-013, seeking authorization to recover costs from contracts with two energy storage projects that were successful bidders in its Spring 2018 RFO on behalf of itself and East Bay Community Energy to procure resources for the Oakland Clean Energy Initiative (OCEI), which will meet reliability concerns in the Oakland subarea.
On May 18, CEERT filed a timely Protest to A.20-04-013, stating that while we have been a “strong vocal and engaged supporter of both the objectives and the process for the OCEI” at both CAISO and the CPUC, unfortunately, our review of the Application demonstrated that the outcome of PG&E’s RFO “fails to measure up to the lofty goals set for the OCEI and sets a terrible precedent for future projects with similar characteristics that are less stark than those related to the OCEI.” Eight other parties filed protests or responses to A.20-04-013, including Sierra Club, the California Efficiency + Demand Management Council, and the Public Advocates Office, to which PG&E filed its Reply on May 28.
On June 18, the CPUC held a Prehearing Conference and CEERT’s party status was confirmed. On July 14, Assigned Commissioner Shiroma issued a Scoping Memo and Ruling, and on August 17 CEERT submitted Opening Testimony, arguing that the Application falls short of goals and expectations and leads to under-procurement, and that the CPUC should remand this Application for further procurement action. On August 28, we submitted Rebuttal Testimony, recommending that the Application be rejected and that in addition to the two storage contracts, PG&E and other LSEs should conduct further procurement of new local preferred resources that would be reasonable elements of a robust, resilient portfolio.
Settlement Conferences were held on September 1 and 8. There have been discussions between the CPUC and parties on the schedule going forward. The September 21 Evidentiary Hearing was vacated.
On September 30, ALJ Fogel issued an E-Mail Ruling with an updated schedule, as follows:
- October 6, 2020: Status Conference
- October 20, 2020: Evidentiary Hearings
- November 12, 2020: Opening Briefs
- December 4, 2020: Reply Briefs
- First Quarter 2021: Proposed Decision
R.18-07-017 (Public Utility Regulatory Policies Act (PURPA) and RPS ReMAT Program Litigation)
As noted in our prior Quarterly Report, on May 7 the CPUC issued D.20-05-006, adopting a new standard offer contract for Qualifying Facilities of 20 MW or less seeking to sell electricity and/or capacity to a CPUC-jurisdiction utility pursuant to PURPA. D.20-05-006 concludes that “[r]evisions to ReMAT, to the extent necessary, is a subject to be addressed in other Commission proceedings.” R.18-07-017 remains open to consider whether further action is required to comply with changes in PURPA regulations that could result from a pending Notice of Proposed Rulemaking that FERC issued on October 4, 2019.
CPUC Gas System and Grid Initiatives
R.20-01-007 – Gas Reliability and System Planning
On July 31, ALJ Tran issued a Ruling Seeking Comments in Track 1 of the gas reliability proceeding on presentations or positions on various issues from workshops held July 7 and July 21. CEERT presented our position on reliability standards at the July 7 workshop, and on August 14 we filed Opening Comments, arguing that the CPUC needs to establish a formal market monitoring system for these and any other relevant data, and routinely publish these data in real time on the CPUC website, along with periodic formal reports on system performance and any recommended regulatory action. We urged the CPUC to broaden the scope of this analysis to more carefully consider the long-term issue of declining gas demand due to success in achieving sound climate policy and rapid deployment of newly competitive non-combustion energy resources.
On September 10, ALJ Tran issued an E-mail Ruling modifying the proceeding schedule as follows:
- October 2, 2020: Public Workshop Report and Staff Recommendations
- November 2, 2020: Comments on Workshop Report and Staff Recommendations
- November 17, 2020: Reply Comments on Workshop Report and Staff Recommendations
- November 20, 2020: Deadline to file a Motion to serve testimony, file briefs and request evidentiary hearings
- January 5, 2021: Intervenor Testimony
- January 20, 2021: Rebuttal Testimony
- January 25-29, 2021: Evidentiary Hearings
- February 8, 2021: Opening Briefs
- February 23, 2021: Reply Briefs
In light of Public Safety Power Shutoffs (PSPSs) during the 2019 fire season, this proceeding is exploring resiliency strategies and microgrid commercialization, as mandated by SB 1339. CEERT is supplying accurate quantification of the benefits that microgrids and other distributed energy resources (DERs) bring to the grid, working to ensure that emission standards aligned with California’s broader clean energy and climate mitigation goals are maintained in the implementation of any resiliency strategy, and pointing out that DERs’ inability to access the RA revenue stream is one of the greatest barriers to full microgrid commercialization. As climate change increases the size and number of wildfires in the West each year, the duration and frequency of PSPSs also increase—and wildfire mitigation and resiliency strategies should not perpetrate the root cause of the need for PSPSs, but must promote clean-energy solutions rather than fossil-fuel generation.
Decision on Short-Term Actions to Accelerate Microgrid Deployment and Related Resiliency Solutions
As noted in our prior Quarterly Report, on April 29 ALJ Rizzo issued a Proposed Decision in Track 1 of R.19-09-009, adopting short-term actions to accelerate microgrid deployment and related resiliency strategies, pursuant to Senate Bill 1339. CEERT filed Opening Comments on May 19 and Reply Comments on May 26, supporting the PD’s reforms to streamline customer-initiated interconnections, but urging that the decision be modified to extend those reforms to other distributed energy resource interconnection projects, and to hold PG&E accountable for implementing clean-energy replacements for emergency fossil generation after this fire season to align with California’s air quality and climate goals.
On June 17, the CPUC issued D.20-06-017, which adopts short-term actions and solutions to accelerate microgrid deployment and interconnection of resiliency projects in advance of the wildfire season, to modernize tariffs to maximize social resiliency benefits, and to promote collaborative engagement between large IOUs and local and tribal governments. The Decision also approves an array of resiliency proposals put forth by PG&E and SDG&E.
Amended Scoping Memo and Ruling for Track 2
On July 3, Assigned Commissioner Shiroma issued an Amended Scoping Memo and Ruling for Track 2 that identified the following issues as being within the scope of Track 2:
- Develop microgrid service standards necessary to meet state and local permitting requirements.
- Develop ways to reduce barriers for microgrid deployment without shifting costs between ratepayers.
- Develop guidelines to determine what impact studies are necessary for microgrids to connect to the electrical corporation grid.
- Develop separate rates and tariffs that are just and reasonable to support microgrids.
- Facilitate the formation of a working group to codify standards and protocols needed to meet California electrical corporation and CAISO microgrid requirements.
- Develop a standard for direct current metering in Electric Rule 21 to streamline the interconnection process and lower interconnection costs for direct current microgrid applications.
The following topics may be addressed in Track 2 or Track 3 of this proceeding:
- Examine the use of advanced metering infrastructure to enable electrical isolation as a viable resilience strategy and potentially adopt a pilot program.
- Determine if large NEM-paired storage should be required to be capable of islanding.
- Develop supplementary parameters for local and tribal governments’ access-restricted portal.
- Address policy questions on local area distribution controllers, such as (but not limited to) third-party integration, operation, and control of a microgrid.
- Initiate activity to shape the transition from diesel generation to clean backup power generation.
Ruling Requesting Comment on Track 2 Microgrid and Resiliency Strategies Staff Proposal
On July 23, ALJ Rizzo issued a Ruling Requesting Comment on the Track 2 Microgrid and Resiliency Strategies Staff Proposal entitled “Facilitating the Commercialization of Microgrids Pursuant to Senate Bill 1339.” A Track 2 workshop on this was held on August 5.
On August 14, CEERT submitted Opening Comments, arguing that the current RA structure for valuing distributed energy resources, hybrids and microgrids must be revised to accurately capture the full suite of benefits these resources provide to the grid, and pay them accordingly. The CPUC must acknowledge that the current RA structure is a major regulatory barrier to the success of the microgrids proceeding.
On August 28, CEERT submitted Reply Comments, noting that multiple parties share our concerns on the need to recognize and address the barriers posed for microgrids by the CPUC’s current RA construct. We argued that microgrid rules and tariffs must be designed holistically, with other parties in mind and in furtherance of California’s broader clean energy and climate mandates. We noted that any microgrid pilot program must be carefully developed to ensure that it yields actual benefits, and that post-workshop party comments on the Staff Concept Paper should be included in the Track 2 record.
In D.20-06-017, the CPUC conditionally approved PG&E’s Temporary Generation Program for the 2020 fire season as a short-term, temporary resiliency solution. A Workshop on diesel alternatives was held on August 25. On September 4, Assigned Commissioner Shiroma and ALJ Rizzo issued a Ruling seeking comments on policy questions about utility deployment of temporary generation, and alternatives to diesel fuel and technology for providing power to customers at safe-to-energize substations during transmission outages. The ruling solicits comment on two issues: an interim approach for minimizing emissions associated with providing temporary power at substations in 2021 while ensuring reliability at just and reasonable rates; and a process for completing the transition to clean technologies and fuels in future years.
In Opening Comments on September 25, CEERT expressed concern that the persisting inability of microgrids and other resiliency technologies to export to the grid will result in ultimately higher costs to ratepayers. We urged the CPUC to explore this issue in depth in the upcoming multiagency workshop in R.19-11-009, and give preference to all non-emitting technologies such as behind-the-meter solar + storage, which is a strong, viable alternative to diesel generation. Any approved diesel generation should be conditioned upon the utility setting a strict timeline with a detailed plan to transition to clean backup energy as soon as possible. DERs and other clean technologies must be valued accurately to incentivize their development and allow them to complete fairly.
While CEERT supports the overall premise of the CPUC’s interim proposals to transition away from diesel generation, we share other parties’ concerns that the workshop and interim proposals treat diesel as the default solution instead of a last-resort backup option after all preferred solutions are exhausted. We continue to push for an expeditious transition away from fossil fuel generation to prevent the conditional approval of diesel generation from persisting beyond when it is truly necessary.
I.17-02-002 – Aliso Canyon
On July 7, ALJ Zhang issued a Ruling Updating the Phase 2 Schedule, as follows:
- August 2020: Ruling issuing Economic Analysis Report
- August-September 2020: Opening and Reply Comments on the Economic Analysis Report
- October 15, 2020: Workshop 4 (Extreme Peak (1-in-35) Hydraulic Results
- Q4 2020: Ruling issuing Production Cost Modeling and Hydraulic Modeling Report
- Q4 2020: Opening and Reply Comments on the Production Cost Modeling and Hydraulic Modeling Report
- Q4 2020 or Q1 2021: Proposed Decision Adopting Modeling Reports
On July 13, CEERT submitted Informal Comments on the July 28 Modeling Workshop #3. We were disappointed in the Workshop, which presented very little information. Much work remains to be done and heroic efforts over the next few months will be required to even begin to answer the question that this proceeding was designed to address.
On July 28, CPUC Energy Division held a workshop wherein they presented results of the Production Cost Modeling, Reliability and Sensitivity cases under peak operating conditions (1-in-10).
On August 26, ALJ Zhang issued a Ruling Entering into the Record Direction to Maintain Aliso Canyon Storage Capacity at or Below the Interim Level of 34 Billion Cubic Feet and Requesting Comment. According to a July 2, 2018 letter from the CPUC’s Executive Director, SoCalGas must maintain capacity at the interim storage level between zero and 34 billion cubic feet. Comments were submitted on September 8 and Reply Comments on September 15.
On September 22, ALJ Zhang issued a Ruling noticing a Workshop for October 15 that will present 1-in-35 hydraulic modeling results, the feasibility assessment methodology and results, winter 2030 1-in-10 sensitivities, and a proposed Aliso Canyon inventory. The key element will be the process for the feasibility assessment of alternatives that may allow the eventual closure of Aliso Canyon.
This proceeding is now three full years in the making and has yet to produce useful results for investment alternatives that would enable Aliso Canyon’s retirement.
CPUC Demand Response (DR). Energy Efficiency (EE), and Building Decarbonization
DR Applications (A.17-01-012, et al.) & Third Party DR Providers Load Impact Protocols (LIPs)
On June 30, Energy Division hosted a workshop to refine technical aspects of the DR Auction Mechanism (DRAM), with two more workshops on this topic held July 15 and August 3. On September 15, PG&E, SCE and SDG&E submitted a Joint Advice Letter seeking approval of their 2022 DRAM Requests for Offers (RFOs) Pilot with an auction in 2021. Responses and Protests were due on October 5.
Prohibited Resources (A.18-10-008, et al.)
On April 13 the record was closed and this proceeding submitted to the CPUC for decision. On September 11, the Public Advocates Office (PAO) filed a Motion to Set Aside Submission and Reopen the Record in order to admit into evidence an August 17 letter entitled “Emergency Action to Combat Heatwave” to PG&E, SCE and SDG&E from then-interim CPUC Executive Director Michelle Cooke. In addition, the PAO seeks to introduce into evidence data request responses from PG&E, SCE and SDG&E on the performance and use of prohibited resources by Base Interruptible Program participants during the August heatwave. A determination on this Motion has not yet been made.
Energy Efficiency (EE) (R.13-11-005)
On July 31, ALJ Kao issued a Ruling Seeking Comments Regarding Natural Resources Defense Council Motion, asking questions on cycle length and budget authorizations, savings goals for IOUs and targets for non-IOU program administrators, flexibility/authority to adjust to changes in market and technology, guidance decision, cost-effectiveness, and technical inputs. Comments were submitted on September 1 and Reply Comments on September 15.
At the August 27 CPUC Business Meeting, the Commissioners voted to adopt Draft Resolution E-5082, which approves Database for Energy-Efficiency Resources (DEER) Updates for Program Year 2022 and a Revised Version for Program Years 2021 and 2020.
On August 31, ALJ Kao issued an E-mail Ruling revising the schedules for the Orders to Show Cause (OSCs) against Southern California Gas Company (SoCalGas). SoCalGas, the Public Advocates Office and Sierra Club filed a Joint Status Update on September 8, and a Status Conference on the OSC Track of the proceeding was held on September 22.
On September 1, PG&E, SCE, SDG&E and SoCalGas submitted their 2021 Annual Budget Advice Letters (ABALs) in compliance with D.15-10-028 (Decision Re Energy Efficiency Goals for 2016 and Beyond and Energy Efficiency Rolling Portfolio Mechanics) and guidance from the CPUC Energy Division Staff. Responses and Protests to the ABALs were submitted on October 1.
On September 16, Sierra Club and NRDC submitted a Motion to terminate SoCalGas’s Energy Efficient New Homes Program (EENH) and sanction SoCalGas for violations of CPUC Rules. Sierra Club and NRDC argue that the CPUC should immediately terminate the EENH Program because it violates well-established CPUC policy requiring efficiency programs to achieve savings above code or industry standard practice, and it incentivizes expanding the gas system in contravention of state requirements for a zero-GHG emissions future. Responses to the Motion are due on October 1.
Building Decarbonization (R.19-01-011)
On August 5, Commissioner Rechtschaffen issued a Phase II Amended Scoping Memo and Ruling. Phase II Issues include incentive layering, a Wildfire and Natural Disaster Resiliency Rebuild (WNDRR) program, and a special baseline allowance for electric water heating equipment. The schedule is:
- September 15: Workshop on WNDRR Proposal, electric baseline adjustment proposal, mobile home park (MHP) electrification and other matters related to building decarbonization.
- October 9: Opening Comments on Staff Proposal and Workshop are due.
- October 16: Reply Comments on Staff Proposal and Workshop are due.
- December 2020: Proposed Decision issued.
A September 15 Workshop was held on the Phase II Building Decarbonization Energy Division Staff Proposal. The Workshop focused on the proposed WNDRR program, lessons learned on the topic of mobile home electrification and rent impacts from post-wildfire mobile home park rebuilds, and the proposed electric water heating baseline allowance. On September 24, ALJ McKinney issued a Ruling setting a Phase II Prehearing Conference for October 9 and seeking comment on the Energy Division Proposal, the Phase II Workshop and specific questions set forth in Attachment A to the Ruling. Comments were due on October 9 and Reply Comments on October 16.
Other CPUC Rulemakings and Governance Actions
To the extent resources are available, CEERT is tracking the following CPUC proceedings that have significance for clean energy policies and, where appropriate, can be the subject of CEERT advocacy.
Self-Generation Incentive Program (SGIP) (R.20-05-012)
On July 17, ALJ Fogel issued an E-mail Ruling noticing a Prehearing Conference on July 29 to consider the proceeding schedule, scope, and other procedural matters. Subsequently, CEERT submitted a Motion for Party Status, which was granted. At the Prehearing Conference, CEERT stated that there needed to be coordination between this proceeding and the IRP and RA proceedings, and on August 4, we submitted a Post-Prehearing Conference Statement, again noting that the Scoping Memo must provide for consideration of and coordination between SGIP, IRP, and the RA Program.
On August 17, Assigned Commissioner Rechtschaffen issued a Scoping Memo and Ruling. The issues to be determined in this rulemaking are SGIP evaluation and oversight requirements, consideration of SGIP program revisions or refinements, and California Solar Initiative sub-program review and evaluation.
On September 16, CEERT submitted Opening Comments on Questions (b) – (k) of the Scoping Memo and Ruling, and expressed appreciation for Commissioner Rechtschaffen’s decision to include coordination of the RA, IRP and SGIP rulemakings within the scope of the proceeding. We recommended that SGIP incentives for electric vehicle storage systems and EVSE be aligned with the IRP and RA programs to ensure best results. Reply Comments on the Scoping Memo and Ruling are due on October 23.
On September 3, Commissioner Rechtschaffen issued a Proposed Decision revising and clarifying eligibility requirements adopted in Decision (D.) 20-01-021 for SGIP equity resiliency budget customers that rely on an electric well pump for their water supply. Such residential customers that reside in a Tier 3 or Tier 2 High Fire Threat District or who have experienced two or more discrete Public Safety Power Shutoff events are currently eligible for equity resiliency budget incentives regardless of income.
This decision revises D.20-01-021 to require equity resiliency budget electric well pump customers to also demonstrate a single-family household income no greater than 80% of area median income or that a multifamily building is either located in a disadvantaged community or demonstrates that at least 80% of building households have incomes at or below 60% of area median income. This decision is effective immediately upon CPUC adoption. The decision directs SGIP Program Administrators to file a Joint Tier 2 advice letter within 20 days of the decision’s issuance proposing changes to the SGIP Handbook to implement the adopted revisions and clarifications. Comments were submitted on September 23 and Reply Comments on September 28.
Power Charge Indifference Adjustment (PCIA) (R.17-06-026)
On August 12, the CPUC issued D.20-08-004, which adopts a framework for prepayment agreements for PCIA obligations. Upon review of the Working Group Two recommendations, this decision (1) adopts the consensus framework of PCIA prepayment agreements; (2) adopts the consensus guiding principles, except for one principle regarding partial payments; (3) adopts evaluation criteria for prepayment agreements; (4) does not adopt any proposed prepayment concepts; and (5) clarifies that risk should be incorporated into the prepayment calculations by using mutually acceptable terms and conditions that adequately mitigate the risks identified by Working Group Two. This decision also directs PG&E, SCE, and SDG&E to file Tier 2 Advice Letters establishing a prepayment request processing framework. The assignment of Working Group Two on the PCIA prepayment issues is considered complete.
Integrated Distributed Energy Resources (IDER) (R.14-10-003)
There has not been much activity in this proceeding since the last Quarterly Report other than to extend the statutory deadline to February 15, 2021.
Distribution Resources Plan (DRP) (R.14-08-013, et al.)
On May 11, ALJ Mason issued a Ruling Modifying the Distribution Investment Deferral Framework (DIDF) – Filing and Process Requirements.
On July 3, ALJ Mason issued a Ruling that orders PG&E to launch a DIDF Request for Offers solicitation for the Estrella Substation distribution deferral opportunity no later than October 30. The solicitation will seek to procure distributed energy resources (DERs) to address the capacity needs identified in PG&E’s 2020 Grid Needs Assessment/Distribution Deferral Opportunity Report filing.
DER Improvements to Rule 21 (R.17-07-007)
On September 24, the Commissioners voted to adopt a Proposed Decision Adopting Recommendations from Working Groups Two, Three, and Vehicle-to-Grid Alternating Current Subgroup. (Final Decision D.20-09-035 has not been issued). The PD modifies Electric Tariff Rule 21 for PG&E, SCE and SDG&E that governs the interconnection of DERs. The primary objective of the modifications is to streamline the interconnection process by incorporating the Integration Capacity Analysis (ICA) results from R.14-08-013, the Distribution Resources Plans (DRP) proceeding.
Public Records Access (R.14-11-001)
On September 3, the CPUC issued D.20-08-031, which declines to adopt any additional confidentiality matrices at this time, but does establish a baseline showing that an information submitter must make to enable consideration of confidential treatment of critical infrastructure information. This new approach will ensure that the CPUC adjudicates confidentiality claims about such information more consistently, and reduce the time-consuming, difficult discretionary decisions on the appropriateness of such claims.
Climate Change Adaptation (R.18-04-019)
On August 27, the CPUC issued D.20-08-046 which is the Decision on Energy Utility Climate Change Vulnerability Assessments and Climate Adaptation in Disadvantaged Communities (Phase 1, Topics 4 and 5). The Decision weaves together two questions: how should the energy utilities assess and adapt to California’s vulnerabilities caused by climate change, and how should the utilities engage with the most vulnerable and disadvantaged communities on climate adaptation related to the utilities’ infrastructure, operations and services so these communities are not left behind the rest of the state.
On June 11, the CPUC issued D.20-06-003, which adopts rules and policy changes applicable to SCE, PG&E, SDG&E and SoCalGas, and is designed to reduce the number of residential customer disconnections and to improve reconnection processes for disconnected customers. The Decision adopts and makes permanent, with modifications, the Interim Rules Decision issued on December 13, 2018. On September 17, the CPUC held a Prehearing Conference, primarily on the Percentage of Income Payment Plan.
On June 9, Assigned Commissioner Rechtschaffen issued a Second Amended Scoping Memo and Ruling. The issues to be determined in the second phase of this proceeding are:
- How to implement the affordability metrics and methodologies adopted by the Commission;
- How to forecast variables used to calculate the affordability metrics;
- How to set proxy values for essential utility service cost data that are unavailable;
- Determining the appropriate procedural pathways for implementation of the affordability metrics generally (i.e., how broadly and in which proceedings to incorporate the metrics as well as the process used to publish information);
- How to design and publish an annual Affordability Report;
- How to refine methodologies for calculating the affordability metrics, including the potential consideration of other nondiscretionary expenses;
- Determining interactions between the affordability metrics and the rate and bill tracker tool under development by the CPUC Energy Division;
- How to coordinate ongoing data requests for information related to the affordability metrics;
- How to develop and maintain tools for calculating the affordability metrics;
- How to make the measurements of the affordability metrics publicly available and accessible;
- How to best ensure coordination with the Disconnections OIR (R.18-07-005) and this OIR; and
- How to incorporate any approved essential usage study from Application (A.) 19-11-019.
The proposed schedule is largely tentative, with the first event being an Initial Annual Affordability Report, which is to be issued in the fourth quarter of 2020.
On July 22, the CPUC issued D.20-07-032, which is the Decision Adopting Metrics and Methodologies for Assessing the Relative Affordability of Utility Service. This Decision defines affordability as the degree to which a representative household is able to pay for an essential utility service, given its socioeconomic status. The Decision adopts three metrics and supporting methodologies for the CPUC to use in assessing the affordability of essential electricity, gas, water, and communications utility services in California. The metrics are: the hours at minimum wage required to pay for essential utility services, the vulnerability index of various communities in California, and the affordability ratio of essential utility service charges to non-disposable household income.
The methodologies for calculating these metrics are necessarily complex and require assumptions on the cost of essential utility services and nondiscretionary household income, using data with known limitations. As a result, the Decision seeks to use the three metrics in concert to give the Commission a more complete picture of the affordability of essential utility services. These metrics account for California’s geographic and economic diversity by relying on data with small granularity. The Decision does not adopt an absolute definition of what constitutes affordable essential utility services, but adopts metrics and methodologies for assessing affordability across utilities over time in a way that is feasible for staff to implement and maintain. This will allow Commission decision-makers and stakeholders to consider the relative impact on the affordability metrics of proposals before the Commission.
Non-Bypassable Charge (R.19-07-017)
On July 24, the CPUC issued D.20-07-014, which approves serving orders to be executed between the California Department of Water Resources and the large electrical corporations to support the collection of the charge adopted in D.19-10-056.
At the September 24 CPUC Business Meeting, the Commissioners voted to adopt a Proposed Decision Adopting Timing and Amount of 2020 Wildfire Fund Non-Bypassable Charge. Final Decision D.20-09-023 has not yet been issued. The Decision adopts an amount for the Wildfire Fund Non-Bypassable Charge for October through December 2020.
Associate Regulatory Attorney