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Green Group Seeks To Impose "Symmetric" Procurement Requirements On Retail Suppliers If Recommended Use of Long-Term PPAs Approved For SOS

November 13, 2018

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Reporting by Paul Ring • ring@energychoicematters.com

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In comments on the structure of electricity SOS in the District of Columbia, the Sierra Club urged the adoption of long-term PPAs for SOS, and further said that, "Sierra Club supports applying PPA requirements for all SOS customer classes, and also for competitive electricity suppliers in addition to SOS."

Sierra Club urged the PSC to utilize PPAs with renewable generation for SOS load, and recommended that contract terms for renewable PPAs be no less than 10 years.

Concerning its proposed requirements for retail suppliers, Sierra Club said, "While the Sierra Club expects, consistent with the PJM PPA [cost] data ... that it will be possible to obtain long-term renewable energy PPAs that are competitive with existing SOS prices, the easiest way to ensure meaningful competition between SOS and competitive electricity suppliers and at the same time mitigate the risk of migration of SOS customers is by ensuring that any renewable PPA requirements are symmetric between SOS and competitive electric suppliers. Absent symmetrical requirements, it will be important for the Commission to think through whether and how departing SOS customers will contribute to legacy long-term contracts."

The Sierra Club faulted the California PUC's Power Charge Indifference Adjustment approach to the issue of utility supply and departing load

Rather, Sierra Club said that, "To mitigate the likelihood of customer migration and need to develop a complicated exit fee in the District, it would be prudent for the Commission to impose equivalent PPA obligations on SOS and competitive electricity suppliers. However, it is advisable for the Commission to identify in advance the construct it will use to address the costs of legacy contracts should a significant amount of customer load migrates from SOS to competitive electricity suppliers."

Sierra Club's comments were filed in the biennial SOS review process

Also see our related story today on Pepco's and other parties' SOS comments: Pepco Now Says SOS Minimum Stay Provision For Non-residential Customers "Could" Be Eliminated

FC 1017

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