Calif. Ruling Requires 10-Year RPS Compliance Horizon from Retail Suppliers

Competitive electric service providers (ESPs) in California will be required to file RPS compliance plans with a 10-year horizon, per an assigned commissioner's ruling from Commissioner Mark Ferron (R. 11-05-005).

As previously ordered in D.11-01-026, ESPs must file RPS procurement plans. ESP procurement plans for 2012 shall be filed by May 23.

While many of the new procurement plan filing requirements of Public Utilities Code § 399.13(a)(5) do not reasonably apply to ESPs, the assigned commissioner's ruling requires that the following provisions apply to the ESP procurement plans:

6.1 Assessment of RPS Portfolio Supplies and Demand - § 399.13(a)(5)(A)
"Provide a written description assessing annual or multi-year portfolio supplies and demand to determine the retail seller's optimal mix of eligible renewable energy resources. In addition, the assessment should consider, at a minimum, a 10-year planning horizon. This written description must include the retail seller's need for RPS resources with specific deliverability characteristics, such as, peaking, dispatchable, baseload, firm, and as-available capacity. It should also address the retail seller's need for and plan for procuring resources that satisfy the three portfolio content categories of RPS procurement. This written description must explain how the proposed renewable energy portfolio will align with expected load curves and durations..."

6.2 Potential Compliance Delays - § 399.13(a)(5)(B)
"Describe in writing any potential issues that could delay RPS compliance, including inadequate transmission capacity and the relationship, if any, to deliveries and project development delays by, for example, permitting, interconnection, or other circumstances. Describe the steps taken to account for and minimize these potential compliance delays ... [D]iscuss how the compliance delays will impact the retail seller's net short and its procurement decisions"

6.3 Project Development Status Update - § 399.13(a)(5)(D)
"Provide a written status update on the development schedule of all eligible renewable energy resources currently under contract but not yet delivering generation..."

6.4. Risk Assessment - § 399.13(a)(5)(F)
"Provide a written assessment of the risk of failure to build or of construction delay for eligible renewable energy resource projects currently under contract.

6.5. Quantitative Information - §§ 399.13(a)(5)(A), (B), (D) and (F)
"...provide quantitative data, methodologies, and calculations relied upon to assess the retail seller's RPS portfolio needs and procurement net short. This quantitative analysis must take into account, where appropriate, the quantitative discussion requirement by sections 6.1-6.4, above. As stated above, the portfolio assessment should be for a minimum of ten years in the future. The responses must be clear regarding the quantitative progress made towards RPS requirements and the specific risks to the electrical corporation's RPS procurement portfolio. Risks may include, but are not limited to, project development, regulatory, and market risks..."