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Parties Comments. Data Sources In general, supplement RETI with sensitivities on cost (SDG&E, CalWEA); in specific, consider decreases in technology costs (GPI, CalWEA, CLECA)

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parties comments
Parties Comments
  • Data Sources
    • In general, supplement RETI with sensitivities on cost (SDG&E, CalWEA); in specific, consider decreases in technology costs (GPI, CalWEA, CLECA)
    • Discussion point: From an analytical results perspective, what is the main driver for considering lower technology costs – higher MWs of specific renewables, lower portfolio cost/rate impact, or both?
    • Discussion point: Given the approach presented by E3 on possible 33% RPS cases (high wind, high solar, high DG), does this suffice or do parties have something else in mind?
parties comments cont d
Parties Comments (cont’d)
  • Data Sources
    • Renewable procurement outside CA (i.e., WECC-wide) should be considered (All Parties), but focus should be on CA-only (DRA)
    • Discussion point: RETI will produce data for some out-of-state resources (BC, WA, OR, NV, AZ, Northern Baja), but these may need to be enhanced to be consistent with in-state RETI resources and supplemented with data from other states (WY, UT, NM).
      • Should one, some or all 33% RPS cases assume:
        • CA-only?
        • RETI geographical scope?
        • WECC-wide resource availability?
      • How should use of RECs factor into the case assumptions?
parties comments cont d1
Parties Comments (cont’d)
  • Data Sources
    • Resource cost should be based on net cost (PG&E) including benefits (LSA, GPI) such as market value (PG&E)
    • Discussion point: RETI uses economic rank methodology which includes benefits (i.e., energy & capacity value). Is this sufficient?
parties comments cont d2
Parties Comments (cont’d)
  • Analytical Approach
    • Supply curve approach is adequate (PG&E, SCE, CalWEA, CLECA)or should be augmented with (production cost or reliability) modeling studies (SDG&E, DRA, UCS/NRDC)
    • Discussion point: Given that CAISO’s 33% integration study will do sophisticated modeling based on outputs (resource build-outs) from staff’s analysis, is a supply curve approach acceptable at this stage?
parties comments cont d3
Parties Comments (cont’d)
  • Analytical approach
    • Study period should go beyond 2020 (UCS/NRDC) with limitations (GPI and DRA) or should stop at 2020 (SDG&E)
    • Discussion point: What analytical approach should we use to study beyond 2020, if at all?
parties comments cont d4
Parties Comments (cont’d)
  • Scenarios Approach
    • In general, parties thought it reasonable to consider alternative RPS scenarios, with one exception (CARE).
    • Staff should explain distinctions between scenarios, plans, and resource build-outs in its proposed analysis (PG&E).
    • The IOUs (PG&E, SCE) emphasize that 33% by 2020 should be an output, not an input of the analysis;
      • Optimal percentage should be driven by cost relative to other GHG abatement measures (SCE, SDG&E);
      • Timeframe should be tied to lead times for transmission (SCE, SDG&E) and mitigation of environmental & regulatory hurdles (SCE)
      • Discussion point: Do parties agree, or should percentage (33%) and timeframe (by 2020) be assumed as inputs?