The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
The recent documents related to A22-05-022 provide a comprehensive update on the state of renewable energy programs in California, focusing on the Net Value Billing Tariff (NVBT) and community solar projects. Here's a breakdown of the key points and positions from various stakeholders:
Discussions include FERC orders related to electric storage and distributed energy resources, emphasizing that community solar facilities and utilities do not engage in wholesale sales.
The treatment of credits from net metering and community solar is debated, with a focus on retail rate design under state jurisdiction.
The document highlights the importance of targeting low-income households and recommends utilizing various funding sources for renewable energy projects.
Suggestions include implementing a net surplus compensation framework and applying it to all surplus energy at the end of the NVBT facility’s Relevant Period.
The NVBT program is praised for its flexibility and contribution to peak load reductions, with a call for the Commission to confirm NVBT resources as load modifiers.
Recommendations include utilizing state and federal funding sources like AB 102 and the Greenhouse Gas Reduction Fund for renewable energy projects.
Emphasizes the importance of automatic enrollment and flat monetary credits on bills for existing program participants.
Discusses the challenges with PURPA prices in attracting developers to community solar projects and suggests using additional funds to incentivize participation.
The documents collectively underscore the potential savings and advantages of deploying NVBT for renewable energy programs in California. Stakeholders urge the Commission to modify or reject the Proposed Decision based on these findings, highlighting the need for a program that benefits all ratepayers, promotes energy efficiency, and ensures participation from low-income households.
Last Week's New Ruling +1
Ruling Overview
This ruling from the California Public Utilities Commission, dated March 6, 2025, establishes the schedule for the 2025-2026 Distribution Investment Deferral Framework (DIDF) cycle. This framework supports the Grid Needs Assessment (GNA) and Distribution Upgrade Project Report (DUPR). Following Decision 24-10-030, the Commission has shifted the focus of the DIDF from solicitation to enhancing transparency in the Distribution Planning Process (DPP).
Key...
Dates in the 2025 DPAG Schedule
Utilities must provide workshop details and agendas at least 10 days prior to meetings.
Last Week's New Petition for Modification +1
Other
Petition Overview
The Bioenergy Association of California (BAC) filed a Petition to Modify Decision 20-08-043 on March 6, 2025. This petition is part of Rulemaking 18-07-003, which was initiated on July 12, 2018, regarding the California Renewables Portfolio Standard Program. BAC seeks modifications to ensure the BioMAT program complies with Public Utilities Code section 399.20(f)(2), which mandates 250 MW of distributed generation bioenergy...
without an end date.
Program Benefits
The petition highlights several benefits of the BioMAT program, including:
BAC proposes the following changes:
The petition cites delays due to COVID-19, supply chain issues, and the enactment of AB 843, which allows Community Choice Aggregators to participate.
Commission Recognition
The Commission has acknowledged BioMAT's benefits in enhancing public health and safety, particularly in wildfire risk reduction and infrastructure protection, as noted in Resolution E-4922. California's climate strategies, including the 2022 Climate Change Scoping Plan and the Short-Lived Climate Pollutant Reduction Strategy, emphasize increased bioenergy production to mitigate pollutants like methane and black carbon. In 2021, CARB recommended phasing out open burning of agricultural waste in favor of bioenergy to improve air quality.
Support from State Plans
Various state plans support bioenergy development for job creation in rural areas, including:
Reports indicate that bioenergy projects generate more skilled jobs compared to other renewable sources, benefiting economically disadvantaged communities, including Tribes. Failure to extend BioMAT, which is set to end on December 31, could result in the loss of federal funding for ongoing projects, such as a $30 million grant awarded to West Biofuels. The Commission's February report indicates that eliminating BioMAT would yield negligible savings for ratepayers, approximately 7 cents per month, while contributing to wildfire mitigation and renewable energy supply.
Project Characteristics
BioMAT projects provide firm, renewable power at competitive costs, particularly in Category 1. They do not require backup generation or storage and offer additional environmental benefits, such as:
BioMAT projects also produce renewable gas, which offers long-duration energy storage, enhances energy reliability, and addresses Short-Lived Climate Pollutants (SLCPs) like methane and black carbon. Forest BioMAT projects can mitigate wildfire risks, reducing electricity costs for ratepayers. Notably, BioMAT projects do not incur costs to ratepayers until they begin producing power, and actual costs are likely lower than theoretical maximums due to limited megawatt procurement.
Price Adjustments
The petition calls for adjusting BioMAT prices for inflation, particularly in Category 1, which has not seen a price change since 2014, despite a cumulative inflation rate of 36%. The proposed adjustment would increase the offering price to $173 per megawatt-hour, aligning it with other renewable power sources. It also recommends removing utility-specific allocations within feedstock categories to enhance BioMAT procurement, as the original reasons for these allocations are no longer applicable.
Recent Developments
Significant changes have occurred since the adoption of Decision 20-08-043, including:
The California Air Resources Board's 2022 Climate Change Scoping Plan calls for forest thinning on 2.3 million acres per year, generating substantial forest waste and enhancing Category 3 feedstocks. A new plan to phase out open burning of agricultural waste in the San Joaquin Valley will increase Category 2 feedstocks in PG&E and SCE service areas.
Allocation Issues
Utility-specific allocations for feedstock categories are outdated, especially with the inclusion of Community Choice Aggregators (CCAs) in the BioMAT program under AB 843. PG&E's Category 2 allocation is nearly exhausted, while SCE's remains largely unused, indicating a mismatch in allocation based on actual feedstock availability. The Commission is urged to revise these allocations to better align with demand and ensure effective procurement of the 90 megawatts required by SB 1122 from agricultural and dairy waste.
Advocacy for Program Extension
BAC advocates for adjustments to the BioMAT program to allow participation in the Low Carbon Fuel Standard and microgrid tariffs, enhancing the utility of BioMAT power and accelerating procurement. On March 3, 2025, Nick Blair, Senior Policy Advocate for the Association of California Water Agencies, submitted a request to California Public Utilities Commission President Alice Busching Reynolds, advocating for the extension of the BioMAT program. The letter emphasizes the program's alignment with state goals, including:
The benefits of extending the BioMAT program, particularly in terms of economic development and environmental protection, significantly outweigh the associated costs, especially considering the financial impacts of wildfires and pollution on utility ratepayers.
Last Week's New Comments +25
Overview
This update provides a summary of the comments submitted on March 3, 2025, regarding the California Public Utilities Commission (CPUC) proceeding R23-10-011 on the Resource Adequacy (RA) Program. The comments reflect a range of perspectives from utilities, trade groups, developers, and advocacy organizations, addressing key topics such as Planning Reserve Margins (PRM), Load Obligation Trading, Procurement Timing, and Energy Storage Frameworks.
Planning...
Reserve Margin (PRM)
Shell Energy North America (US), L.P. supports a 17% PRM with a 21% effective PRM for June through September, cautioning against higher PRMs due to potential cost increases. Southern California Edison Company (SCE) advocates for maintaining a 17% PRM, critiquing studies that suggest higher margins. Terra-Gen, LLC endorses Western Power Trading Forum's (WPTF) PRM of 21.0% in off-peak months and 22.5% in summer. San Diego Gas & Electric Company (SDG&E) also supports a 17% PRM with a 21% effective PRM during peak months. American Clean Power - California recommends a 21% PRM for peak periods to meet reliability standards, while the California Environmental Justice Alliance (CEJA) favors maintaining a 17% PRM to control costs.
Load Obligation Trading
Shell Energy North America (US), L.P. endorses CalCCA’s proposal for hourly load obligation transactions to help Load Serving Entities (LSEs) meet RA requirements efficiently. California Community Choice Association (CalCCA) also supports implementing hourly load obligation trading, suggesting a 25% limit to enhance procurement efficiency. San Diego Gas & Electric Company (SDG&E) opposes CalCCA’s hourly trading proposal due to its complexity and potential impact on grid reliability. The Alliance for Retail Energy Markets (AReM) backs CalCCA’s trading proposal, advocating for clear transaction logging and compliance rules.
Procurement Timing
Shell Energy North America (US), L.P. opposes Southern California Edison’s (SCE) request to alter procurement timing provisions and supports limiting Mid-Term Reliability (MTR) bridge requirements to summer months. San Diego Gas & Electric Company (SDG&E) recommends revising procurement timelines to enhance flexibility and equitable treatment of LSEs. California Community Choice Association (CalCCA) rejects SCE’s proposal to modify RA Capacity Procurement Evaluations (CPE) timelines, emphasizing the benefits of early allocations for better planning.
System RA Waiver Process
Shell Energy North America (US), L.P. expresses concerns about the proposed System RA waiver process, warning it could lead to costly procurements and inequitable cost allocations. Terra-Gen, LLC opposes the Energy Division’s temporary System RA waivers, advocating for a clear PRM structure instead. The California Independent System Operator Corporation (CAISO) also criticizes the waiver process, indicating it may undermine RA procurement and reliability.
Long Duration Energy Storage (LDES)
Southern California Edison Company (SCE) rejects LDES proposals that do not prioritize reliability, calling for stringent charging requirements for battery storage. Terra-Gen, LLC opposes Hydrostor's proposal to eliminate multi-cycle capabilities under the Slice of Day (SOD) framework, arguing it undermines reliability. The California Energy Storage Alliance (CESA) also opposes minimum LDES procurement requirements and advocates for accurate methods to reflect storage capabilities. Pacific Gas and Electric Company (PG&E) suggests extending battery storage duration thresholds and opposes certain storage-related proposals that could increase costs.
Unforced Capacity (UCAP) Methodology
Shell Energy North America (US), L.P. urges the adoption of CalCCA’s hourly load obligation trading to optimize RA resources. American Clean Power - California (ACP-California) supports modifications to the UCAP framework for thermal and storage resources, advocating for accurate outage data. The California Energy Storage Alliance (CESA) recommends a resource-specific UCAP methodology and opposes the Energy Division's supply cushion hour approach. REV Renewables LLC emphasizes the need for clear definitions of forced outages and supports CESA's equal-weighted best three years methodology.
Support for Early Allocations
Shell Energy North America (US), L.P. opposes SCE’s attempt to reverse recent decisions on CPE procurement timelines, highlighting the benefits of early allocations. San Diego Gas & Electric Company (SDG&E) supports SCE’s revisions to RA penalty structures and procurement rules to enhance compliance flexibility. California Community Choice Association (CalCCA) advocates for allowing LSEs to address deficiencies before deadlines, supporting early and flexible resource management.
Energy Storage Framework
Terra-Gen, LLC supports CESA’s framework for developing UCAP accreditation and opposes Hydrostor’s limitations on storage resource capabilities. The California Energy Storage Alliance (CESA) advocates for recognizing the full dispatch capabilities of storage resources and opposes de-rating for transmission outages. Advanced Energy United emphasizes the need for accurate and equitable storage resource methodologies to ensure reliability and cost-effectiveness.
Critique of LOLE Study Methodology
Southern California Edison Company (SCE) critiques the Energy Division's LOLE study for methodological errors that overestimate PRM requirements. San Diego Gas & Electric Company (SDG&E) also criticizes Hydrostor’s Local Distributed Energy Storage (LDES) capacity requirements, arguing they contradict Integrated Resource Planning (IRP) goals. CAISO warns that the amended LOLE study could weaken RA procurement and reliability standards.
Support for PRM and UCAP Adjustments
Calpine Corporation supports the Energy Division's UCAP proposal and advocates for PRM adjustments to align with a 1-in-10 LOLE. REV Renewables LLC supports refining UCAP methodologies and opposes the Energy Division's volatile accreditation methods. The California Energy Storage Alliance (CESA) recommends accurate and equitable UCAP methods, supporting the adoption of their own proposals for forced outage definitions and resource-specific methodologies.
Additional Recommendations
The California Environmental Justice Alliance (CEJA) emphasizes balancing reliability, affordability, and environmental goals, advocating for accurate RA calculations and increased clean resource valuation. The Clean Energy Buyers Association (CEBA) recommends maintaining a robust PRM and supports RA trading to mitigate cost impacts. The Alliance for Retail Energy Markets (AReM) calls for maintaining the current 17% PRM and endorses CalCCA’s load obligation trading proposal to enhance procurement efficiency.
Last Week's New Ruling +1
Initiation of Rulemaking
On February 20, 2025, the California Public Utilities Commission initiated Rulemaking 25-02-005 to update and reform the Energy Resource Recovery Account (ERRA) and Power Charge Indifference Adjustment (PCIA) policies.
Rulemaking Process
This ruling establishes a two-track schedule for the rulemaking process.
Staff Report
Th...
e Energy Division has prepared a staff report for the 2024-2025 RA MPB, which is included as Appendix A in this ruling. Parties involved are required to incorporate comments on this staff report in their opening and reply comments regarding the Order Instituting Rulemaking.
Issuance of Ruling
The ruling was issued on February 26, 2025, by Chief Administrative Law Judge Michelle Cooke in San Francisco.
Last Week's New Proposed Decision +1
Other
Overview
This proposed decision from the California Public Utilities Commission addresses Phase 2 issues related to Pacific Gas and Electric Company (PG&E) and outlines several key determinations.
Key Determinations
Last Week's New Ruling +1
Ruling Date
On February 25, 2025, the California Public Utilities Commission issued a ruling regarding the Resource Adequacy Program.
Workshops
Following workshops held on February 12 and 13, 2025, Energy Division Staff presented findings on:
Supporting Documents
The updated workshop slides and the Load Migration Update are attached as Appendices A and...
B, respectively.
Comment Schedule
Parties are invited to submit comments on these documents by:
This schedule follows the guidelines established in the Assigned Commissioner’s Amended Scoping Memo from November 1, 2024.
