East Los Angeles Solar Microgrids Feasibility Study
In partnership with Los Angeles County, the Clean Coalition produced a Solar Microgrids Feasibility Study showcasing the resilience benefits and electricity bill savings to LA CountyRead More
We influence energy regulation on the national and state levels by providing decision-makers with information, analysis, and proven solutions. To advance forward-looking energy policies, the Clean Coalition is in the trenches shaping regulatory processes that result in decisions that can make or break our nation’s clean energy future. Below is a list of filings and related documents that the Clean Coalition has officially submitted in 2019 and 2020. For the previous decade of Clean Coalition filings, see this page.
CEC: DER Order Instituting Information (OII) — Comments on Kickoff Workshop | 17 June 2022
In these opening comments on the Order Instituting Information on Distributed Energy Resources (DER) in California’s Energy Future, the Clean Coalition poses a series of important questions to guide the focus of the proceeding. We consider what role DER will play in California’s energy transition, how to maximize the value of DER, the mechanisms necessary to cost-effectively procure DER, how DER should be included in the grid planning process, whether DER have a level playing field compared to other resources, and the role that interconnection plays in DER procurement. Clean Coalition comments also asks the CEC to reflect on the outcomes of this proceeding and whether lessons learned will be sent to the legislature (if significant changes are required).
CPUC: Net Energy Metering — Opening Comments on ALJ Ruling Setting Record Aside and Taking Comments | 10 June 2022
In opening comments, the Clean Coalition takes a strong stand against extending nonbypassable charges to gross consumption of NEM facilities. We demonstrate that self-consumption is similar to energy efficiency since no energy utilizes the utility grid and use the example of Facade-Integrated Solar as a case study, first showing the similarities with energy efficiency and then backing up the claim that Facade-Integrated Solar should be exempt from NEM/interconnection rules.
CPUC: Avoided Cost Calculator (IDER) — Reply Comments on Proposed Decision | 26 April 2022
In reply comments, we reiterate our support for a stronger avoided transmission value by requesting that the Commission assign an interim value for SCE, calling for an “unspecified transmission value” to consider the value of deferring non-planned transmission upgrades and urging the Commission to deny PG&E’s proposal to remove the word “uncontested” from the findings of fact. We also scrutinize the Coalition of Utility Employee’s proposal to cut the avoided distribution value by 98% and request that the Commission prioritize accuracy over harmonizing the Avoided Cost Calculator with the Integrated Resource Planning process.
CPUC: Avoided Cost Calculator (IDER) — Opening Comments on Proposed Decision | 19 April 2022
In opening comments, the Clean Coalition supports updated avoided transmission values for PG&E, but requests that the PUC adopt an interim value for SCE until a full calculation can be completed. We also underscore the need for a grievance process to remedy egregious errors if the Commission removes the minor update process and suggest that any gas forecast prices need to take short-term price fluctuations into account.
CAISO: 20-Year Transmission Outlook — Comments on Draft Report | 22 February 2022
In comments, the Clean Coalition praises the creation of a long-term transmission roadmap, albeit we advocate that the final report should include potential investments in distributed energy resources (DER) as part of the scenario planning process to prevent over-investment in transmission, keeping electric rates from skyrocketing. Our comments detail the ways in which DER can avoid transmission investment and demonstrate, via the Vibrant Clean Energy study, the significant ratepayer savings that come from a balanced grid planning process.
CPUC: Microgrids — Reply Comments on Microgrid Incentive Program Implementation Plan | 28 January 2022
In reply comments, the Clean Coalition underscores the need to extend the project commercial operations date, requests specified interconnection timelines, advocates for a single program website and suggests that the application scoring should reward applicants for projects that serve more customers instead of capping points in that category.
CPUC: Microgrids — Opening comments on Microgrid Incentive Program Implementation Plan | 14 January 2022
In opening comments, the Clean Coalition requests changes to make the Microgrid Incentive Program a deterministic program, where applicants will have certainty that a high application score will lead to approval and the eventual deployment of a Community Microgrid. To ensure this is possible, we advocate for allowing expedited approval of applications fully funded by third parties, urge the IOUs to publish information about Application Intake Windows in advance and streamline interconnection to ensure applicants can achieve their initial commercial operations date.
CPUC: DER Deferral — Comments on Draft Resolution E-5190 | 14 January 2022
In comments on the Draft Resolution, the Clean Coalition supports the changes and requests a few amendments before the Commission approves a Final Resolution. We request uniformity among the three IOUs through the selection of a single Independent Evaluator, applaud the inclusion of a DERMS analysis and propose the inclusion of other emerging DER in the DER Deferral Pilots, such as d-STATCOMS.
CPUC: NEM — Reply comments on proposed decision | 14 January 2022
In reply comments, the Clean Coalition notes that the Commission incorrectly relies on the Ratepayer Impact Measurement test rather than the Total Resource Cost test as the main cost-effectiveness test (and does not use a Societal Cost Test at all). We also address the fact that the Commission’s focus on solar+storage adoption will lead to a drastically lower level standalone solar adoption in all communities and urge rejection of the PD based on lackluster consideration of the full range of party proposals related to energy storage.
CPUC: NEM — Opening comments on proposed decision | 7 January 2022
In opening comments, the Clean Coalition explains why the Proposed Decision will drive ratepayers away from using NEM by making non-export options more economical. We demonstrate that the proposed Grid Participation Charge is an illegal distortion of Transmission Access Charges, which should not be assessed to NEM customers, and critique an insufficient allowance for facilities preparing for electrification to oversize their PV system.
CPUC: Renewable Market Adjusting Tariff — Reply comments on proposed decision | 6 December 2021
In reply comments, the Clean Coalition underscores the importance of using Time of Delivery factors to incentivize the export of energy during peak grid periods and explains why it is necessary for SDG&E to reopen its ReMAT program to meet state procurement requirements.
CPUC: Renewable Market Adjusting Tariff — Opening comments on proposed decision | 30 November 2021
In opening comments, the Clean Coalition supports aspects of the Proposed Decision, including the addition of co-located storage, reopening SDG&E’s queue, notifying queue customers of tariff changes, and expanding eligibility to facilities with shared transformers. However, we disagree with the Commission about flexible product categories and instead request a single product category combined with time of delivery factors to optimize the program with the addition of co-located storage.
CEC: Research on Valuation of Investments in Electricity Sector Resilience — Written comments for the docket | 19 November 2021
Clean Coalition comments urge the Energy Commission to consider our value-of-resilience (VOR) methodology, VOR123, and Resilient Energy Subscription (RES) market mechanism in its research on the valuation of investments in electricity sector resilience. VOR123 and RES will provide a pathway to the widespread deployment of Solar Microgrids and Community Microgrids, as well as helping to finance and expand Community Microgrids.
CPUC: Microgrids for Emergency Reliability — Reply comments on the Track 4 Phase 1 proposed decision | 16 November 2021
Clean Coalition reply comments remind the Commission that the core principle of this proceeding is to increase the commercialization of microgrids and that the decision making process should continue to prioritize input from local governments and tribal communities. With that in mind, we urge the Commission to approve the Regional Microgrid Pilot Program proposed by the County of Los Angeles.
CPUC: Microgrids for Emergency Reliability — Opening comments on the Track 4 Phase 1 proposed decision | 10 November 2021
Clean Coalition comments critique the Proposed Decision for ignoring the vast majority of party proposals and failing to reduce the inhibitions to the widespread proliferation of microgrids. We urge the Commission to consider the proposal made by the County of Los Angeles to deploy Critical Facility Community Microgrids and then explain why a Resilient Energy Subscription (RES) is the missing piece needed to cost-effectively expand a Community Microgrid at the cost of service.
CPUC: Microgrids for Emergency Reliability — Opening comments on the Track 4 Phase 1 proposed decision | 10 November 2021
In these Joint Comments, parties lambast the Commission for taking a step in the wrong direction by approving fossil-fuel generation. In addition, comments point out the inherent cost shift in SDG&E’s proposal and decry the Commission’s choice to reject the majority of party proposals as a sign that it isn’t properly carrying out the mandate laid out in the Governor’s Emergency Proclamation.
FERC: Transmission Planning — Reply comments | 9 November 2021
The Clean Coalition advocates that the Federal Energy Regulatory Commission’s rulemaking on regional transmission planning prioritize transparency, precise cost allocations, and transitioning to a two-way grid powered by distributed energy resources (DER). As an example, our comments point to the current market distortion caused by the inaccurate assessment of Transmission Access Charges (TAC) at the customer meter rather than at a transmission-distribution substation. We also note that even as transmission costs continue to drive up electric rates, the majority of utility transmission projects (greater than 80% in the case of PG&E from 2016-2019) are self-approved. Building an efficient grid requires balancing state and local needs in an effort to supply clean energy at the lowest cost to the consumers, not just building more unvetted transmission infrastructure.
CPUC: Draft DER Action Plan 2.0 — Informal comments | 8 October 2021
In these informal comments, the Clean Coalition calls on the Commission to acknowledge the value of DER and offers a series of action items, which can mostly be implemented in the next year and a half, to speed up the transition to a two-way grid. We focus on policy revisions that will change the planning process, including reforming the DIDF to include all clean DER, improving ICA/Data Portals to benefit developers, automating BTM interconnection, streamlining FOM interconnection, and implementing Performance Based Regulation in the near-term.
CPUC: High DER OIR — Reply comments on OIR | 7 October 2021
In these reply comments, the Clean Coalition requests that the proceeding be structured in parallel tracks, allowing low-hanging-fruit-solutions to be implemented quickly, while longer systematic change is properly studied. We suggest addressing ICA issues and Performance Based Regulation in the short-term and the value of resilience, DER opportunities assessment, and a solution to Transmission Access Charges in the long-term.
CPUC: Microgrids — Reply to Opening Comments in Response to Emergency Proclamation Proposals | 1 October 2021
In reply comments, we recommend the approval of behind-the-meter distributed generation aggregations and Community Microgrids rather than continuing to rely on temporary contracts with fossil fuel generators. Due to looming reliability concerns, we also support a relaxation of Rule 18/19 rules on private energy sharing between adjacent properties and continue to stress the importance of swift interconnection reform.
CPUC: Proposed Preferred System Plan — Opening comments in response to ALJ ruling seeking questions | 27 September 2021
The Clean Coalition comments express surprise that the Load Serving Entity’s Integrated Resource Plans did not meet either reliability or GHG reduction goals. We criticize the proposed Preferred System Plan as failing to consider DER as an alternative to transmission-interconnected resources, particularly with the increasing demand for resilience. Opening comments conclude by briefly introducing our Resilient Energy Subscription (RES) proposal, a way to fund Community Microgrids, which add a layer of local resilience and reduce congestion on the transmission system.
CPUC: Microgrids — Opening comments in response to emergency proclamation proposals | 24 September 2021
Using examples from the VGES Front-of-Meter Energy Storage Interconnection Case Study, Clean Coalition comments underscore the need for front-of-meter interconnection reform to truly enable Community Microgrids. We also urge the Commission to consider a joint report we drafted with the Green Power Institute on Automation on the behind-the-meter interconnection process.
CPUC: NEM 3.0 — Reply briefs | 22 September 2021
In reply briefs the Clean Coalition explains that the Successor Tariff should be crafted based on the intent of the original legislation: to ensure the sustainable growth of renewable technologies. We urge the Commission not to push ratepayers away from NEM with punitive fees for transmission and access to the grid and instead maximize benefits to the grid with a Feed-In Tariff for larger NEM systems. Our comments support extending VNEM, reforming NEM-A, and guaranteeing a reasonable payback period for all NEM systems.
CPUC: Order Instituting Rulemaking to Modernize the Electric Grid for a High DER Future — opening comments | 16 August 2021
Clean Coalition comments applaud the CPUC for developing a streamlined proceeding to manage the future of DER and optimize a two-way grid. We advocate for a full study of a DSO model (including all ownership models), the importance of reconsidering Transmission Access Charges/avoided transmission values, and creating a framework to balance all solutions as part of the distribution planning process.
CPUC: Proposed Decision on Order Closing Rulemaking 14-10-003 — reply comments | 26 July 2021
Clean Coalition reply comments support the opening comments of 350 Bay Area in requesting a full and detailed list of the proceeding’s history. We argue that the new High DER Planning proceeding (R. 21-06-017) can only succeed with a thorough foundation of everything that has been completed or still needs to be finished from the IDER proceeding. We provide an example of the recent confusion over what constitutes a Minor Update versus a Major Update to the Avoided Cost Calculator as an opportunity to demonstrate where progress has been made in the IDER proceeding, but CPUC clarity is needed.
CPUC: NEM 3.0 Direct Testimony — rebuttal testimony | 16 July 2021
In Rebuttal Testimony, the Clean Coalition points out the absurdity of charging a Grid Benefits Charge (GBC) based solely on on-site consumption and explains why CPUC precedent requires the use of the Total Resource Cost test as one of the main tools to measure the cost-effectiveness of DER. Our testimony exposes the flawed assumptions involved in the creation of proposed GBCs and details the multiple ways in which DER can defer transmission buildout.
CPUC: Microgrids — reply comments | 6 July 2021
In reply comments the Clean Coalition notes that the CPUC has not done a comprehensive analysis of the benefits a microgrid provides, nor has a study of any costs to the grid been completed. As a result, the proceeding has been needlessly limited, and while the Proposed Decision is an important step forward, it is only a portion of much broader solution necessary to overcome the barriers to the commercialization of microgrids.
CPUC: Microgrids — opening comments | 29 June 2021
In these opening comments on the Proposed Decision, the Clean Coalition supports the proposed exemption for microgrids from capacity reservation charges, and urges the CPUC to take it a step further. We request that all emergency charging situations prior to widespread outages not be counted toward increased demand charges and suggest that verification of microgrids be dependent on the emissions from component resources. Comments conclude by suggesting that microgrids that export fully during the critical peak period of the day should receive a full exemption from non-bypassable charges.
CPUC: DER Deferral Evaluation and Performance Criteria Implementation Advice Letter — protest of AL 3780-E | 23 June 2021
The Clean Coalition protests the Joint Utility’s implementation plan, arguing that the Distribution Planning Advisory Group (DPAG) should hire the Independent Evaluator (IE) for the program and only choose to ramp down one of the two pilots if there is a request from both the utility and the IE. We also request an analysis of DERMS for each pilot, to ensure that short-term results do not count against the long-term success of DER deferral.
CPUC: ALJ Ruling Seeking Updated Information Regarding the Renewable Market Adjusting Tariff Program — reply comments | 23 June 2021
Clean Coalition reply comments explain why now is the right time to amend ReMAT in order to regain market confidence, request that the CPUC consider expanding program allocations, demonstrate the need to remove product categories, and implement time-differentiated TOD factors, and we urge the CPUC to adopt a locational adder.
CPUC: NEM 3.0 Direct Testimony — opening testimony | 18 June 2021
In our testimony, the Clean Coalition focuses on pushing back against a grid benefits charge, especially one that would charge NEM customer Transmission Access Charges. We also underscore how essential it is for ratepayers that the debate over the Successor Tariff is not limited to the residential aspect of the tariff, precluding changes to the way V-NEM, NEM-A, and larger NEM systems are billed.
CAISO: Aggregate Constraint Capabilities Final Draft Tariff — comments | 14 June 2021
The Clean Coalition lauds CAISO’s final tariff as enabling the use of software controls as a technique to impose separate output limits at the point of interconnection, allowing multiple off-takers from a single project. We use the example of the Clean Coalition’s Valencia Gardens Energy Storage (VGES) project to demonstrate that with an option for Aggregate Constraint Capabilities, the original two-battery energy storage system design could have moved forward, rather than requiring a shift to a single smaller energy storage system.
CPUC: Comments on Advanced DER & Flexibility Management Workshop | 11 June 2021
Clean Coalition comments support Energy Division’s Real Time Pricing Proposal as an important step toward achieving more granular and transparent energy costs that will reduce the barriers to market entry for ratepayers interested in renewable energy systems. In particular, we note the importance of using an avoided cost framework to properly value the benefits of distributed energy and of including a Value of Resilience. Comments also emphasize the importance of deploying Distributed Energy Resources Management Systems (DERMS) to manage DER in real time and respond accordingly, optimizing the function of a two-way grid.
CPUC: ALJ Ruling Seeking Updates Information Regarding the Renewable Market Adjusting Tariff Program — opening comments | 9 June 2021
Clean Coalition opening comments advocate for the consolidation of the three ReMAT product categories into one large category with TOD multipliers to incentivize the deployment of co-located storage in order to maximize the value of energy exported to the grid. In addition, to ensure that full capacity is reached, we recommend that the CPUC change the definition of “fully subscribed,” remove de minimis status entirely, and reopen SDG&E’s ReMAT program.
CPUC: Avoided Cost Calculator (IDER) — reply comments | 1 June 2021
In reply comments, the Clean Coalition poses three questions and correlates a “no” answer to each question as providing the CPUC with sufficient reason to reject the proposed 2021 Minor Update. First, is there a consensus among parties that the changes are minor? Second, was the CPUC-specified procedure for a Minor Update followed? Third, can the CPUC be sure all inputs are accurate and will not result in unforeseen consequences?
CPUC: Avoided Cost Calculator (IDER) — opening comments | 24 May 2021
Clean Coalition comments critique the CPUC for attempting to sneak major changes into the Avoided Cost Calculator during a Minor Update cycle. The changes, which slash the value of standalone solar by 70%, did not go through a thorough public evaluation by stakeholders and rely on untested/unapproved modeling tools. We address improper inputs to the model, including the use of temperature data from 2013 to model heat rates in 2030, and explain why the missteps result in a drastically lowered avoided cost of DER when compared to the 2020 ACC.
CPUC: NEM Fuel Cell Tariff — reply comments | 17 May 2021
While the Clean Coalition acknowledges in comments that the NEM Successor Tariff should also apply to fuel cells, we strongly support proposals to require verification — via an independent inspector — to guarantee that no methane leakage is occurring before a facility is allowed to officially take serve under the tariff. We also support comments made by Protect our Communities Foundation advocating for the CPUC to request new acceptable greenhouse gas emission levels for fuel cells (from the California Air Resources Board).
CPUC: Rule 21 Track 1 Interconnection Proposed Decision — reply comments | 3 May 2021
Clean Coalition reply comments argue that the proposed two-year timeline for soliciting new interconnection issues needs to be shortened to ensure that the CPUC does not fall further behind at creating regulation than in the past. Our comments also advocate for the creation of single-line diagrams for Zero Net Energy projects, to ready the Joint IOUs for the influx of interconnection requests from new constructions complying with energy efficiency mandates.
CPUC: Provider of Last Resort — opening comments | 26 April 2021
Clean Coalition opening comments acknowledge the importance of discussing details about how the provider of last resort will operate in California and suggest that guidelines and a tentative schedule for inter-agency cooperation should be set within 30 days of the prehearing conference.
CPUC: DER Deferral Evaluation and Performance Criteria — reply comments | 14 April 2021
Clean Coalition reply comments aim at ensuring the pilots are administered all the way through to the original deadlines approved by the CPUC; we agree with a statement made by Cal Advocates that the pilots should continue if there is any long-term pathway to success. Furthermore, we acknowledge that analysis of the pilots should consider how the value of a long-term program might change with the inclusion of Distributed Energy Resources Managements Systems, which can optimize the value of a DER aggregation that includes resources deployed on both sides of the meter.
CPUC: DER Deferral Evaluation and Performance Criteria — opening comments | 9 April 2021
Clean Coalition comments argue that the most important way to evaluate these new pilots is to gather as much data as possible to understand the big picture, including resource types for each project, changing market conditions, the number of deferral needs met each year, and the type of aggregators bidding to meet the demand. We also argue that resources should receive value for the system benefits they provide in addition to deferring the need for distribution upgrades, such as greenhouse gas reduction and avoided tranmission. Comments conclude by suggesting that the CPUC should evaluate whether allowing aggregations of resources on either side of the meter, rather than separate pilots for behind-the-meter and front-of-meter resources, would optimize the value of DER.
CPUC: Proposed Successor to the Net Energy Metering Tariff | 15 March 2021
The Clean Coalition party proposal focuses on a few key areas rather than outlining a full Successor Tariff. We advocate for the development of a Feed-In Tariff (FIT) similar to the LADWP FIT+ Pilot Program, argue that Transmission Access Charges (TAC) should not be included in the final list of non-bypassable charges in the Successor Tariff, and suggest that all meters participating in aggregations for NEM-A be exempt from demand charges. Comments touch on the need for valuing resilience for paired storage and the benefits of including a pathway for sites to over-generate in preparation for a load increase associated with electrification.
CPUC: Microgrid Track 3 Amended Scoping Memo and Questions — reply comments | 10 March 2021
Our comments focus on the fact that all parties agree that discussing microgrid exemptions to standby charges is premature without first quantifying the value-of-resilience (VOR). The Clean Coalition underscores the need for the Commission to approve standby-charge reform in the microgrids proceeding and calls for exemptions for small microgrids under 1 MW and critical community facility microgrids.
CPUC: Microgrid Track 3 Amended Scoping Memo and Questions — opening comments | 3 March 2021
Clean Coalition comments make it clear that discussing exemptions to standby charges without defining and quantifying the grid services a microgrid can offer — resilience, in particular — makes the debate much less meaningful and granular than it otherwise would be. We argue that standby charges are outdated and the concept of the utility as the “provider of last resort” does not account for the reliable service a microgrid provides. We conclude that the Commission needs to entirely reform standby charges and that exemptions should be granted for multiple different types of microgrids, including critical community facility microgrids, microgrids that provide grid services, and microgrids completely disconnected from the grid.
CPUC: Proposed Decision Directing PG&E, SCE, and SDG&E to Seek Contracts for Additional Power Capacity for Summer 2021 — reply comments | 2 February 2021
In reply comments, the Clean Coalition aligns with party positions arguing that this proceeding should be used to set the stage for long-term solutions deployed in 2022, 2023, and beyond. While we still push for the necessary prioritization of energy storage, we suggest that the Commission tie energy storage together with other renewable resources in the optimal configuration, a series of Community Microgrids. Comments include Clean Coalition analysis showing that Community Microgrids are a more economical investment than gas peaker plants.
CPUC: Proposed Decision Directing PG&E, SCE, and SDG&E to Seek Contracts for Additional Power Capacity for Summer 2021 — opening comments | 28 January 2021
Clean Coalition comments request that the Commission prioritize the procurement of energy storage over any investments in fossil fuel generation. We argue that energy storage is dispatchable and offers other benefits to the electrical system — resilience, a reduction in greenhouse gas emissions, and lower demand during peak hours — that fossil fuel generation cannot compete with.
CPUC: Proposed Decision Adopting Guiding Principles for the Development of the Successor to the Current Net Energy Metering Tariff — opening comments | 25 January 2021
The Clean Coalition argues that the Proposed Decision should include a guideline about promoting energy storage. Our comments demonstrate that if Principle 5 — using a technology-neutral approach — is amended to specify “eligible generation resources,” the addition of a guideline about energy storage will complement rather than conflict with it. Comments conclude by pointing out the need for the Commission to prioritize guidelines that create specific metrics to be used when judging the success of a tariff. We identify the guideline about “considering fair competition between electric service providers” as an example of one that is difficult to prove one way or the other.
CPUC: Proposed Decision Adopting Pilots to Test Two Frameworks for Procuring Distributed Energy Resources that Avoid or Defer Utility Capital Investment — opening comments | 25 January 2021
In opening comments, the Clean Coalition offers support for the two pilots, also suggesting that the Commission should consider making the pilots permanent during the mid-project review rather than waiting five years for the scheduled end of the pilots if clear benefits are evident early on. The mid-project review should consider ways to optimize aggregations, including combining behind-the-meter and front-of-meter projects. We urge the Commission not to forget the importance of Distributed Energy Management Systems, which the utilities are not required to develop in the current iteration of the Proposed Decision. Comments conclude with an argument for the inclusion of a market-adjusting cost cap and a discussion of two scenarios where the use of a Feed-In Tariff would greatly benefit the deferral tariff.
CPUC: Ruling Directing Responses to Questions on Rule 21 Working Group 4 Report and Issues 11 and 13 — reply comments | 8 January 2021
In these reply comments, the Clean Coalition replies to the three parties in opposition — California’s three investor-owned utilities — to the proposal we sponsored, which would require the creation of template single-line diagrams for Zero Net Energy (ZNE) facilities. We reiterate that the proposal is a simple but elegant solution for streamlining interconnection by proactively reducing the imminent increased demand on interconnection staff as an influx of ZNE applications are submitted.
CPUC: Microgrid Track 2 Proposed Decision Comments — reply comments | 4 January 2021
In this reply to opening comments, we agree with parties that the Commission should make a strong statement to the legislature about the need to change the over-the-fence rule (section 218(b) of the Public Utilities Code). We also concur with the Microgrid Resources Coalition about the need for clarify foundational definitions such as “commercialization” and “cost-shifting,” adding the “value of resilience” as another phrase that will change the outcome of the proceeding. We end with a request that the Commission further discuss the value of microgrid grid services and specify some of the unintended consequences that caused them to limit proposals during Track 2.
CPUC: Microgrid Track 2 Proposed Decision Comments | 28 December 2020
Clean Coalition comments open with a strong critique of the Commission for rushing Track 2 of the proceeding, ultimately culminating with a Proposed Decision that does not achieve any of the goals listed in SB 1339 — commercializing microgrids and reducing greenhouse gases — and that does not even attempt to quantify the value-of-resilience (VOR). We make a number of suggestions, including calling for all critical facilities to be eligible for the Rule 18/19 exemption, asking for microgrid grid services and resilience to be valued in a microgrid rate schedule, and requesting that the utilities be held to a stricter standard for transitioning to renewable microgrids for substation-level backup power.
CPUC: Ruling Directing Responses to Questions on Rule 21 Working Group 4 Report and Issues 11 and 13 — opening comments| 18 December 2020
In opening comments, the Clean Coalition supports proposals that would reduce interconnection times related to anti-islanding studies, including a proposal requiring generation-to-load calculations to be performed with hourly profiles and a proposal to speed up the process by allowing applicants to hire utility-approved experts for a more detailed study. The majority of comments focus on responding to questions related to the proposal submitted by the Clean Coalition to require the creation of template single-line diagrams for Zero Net Energy facilities.
CPUC: Joint Assigned Commissioner’s Scoping Memo and Administrative Law Judge Ruling Directing Comments on Proposed Guiding Principles Related to Net Energy Metering | 11 December 2020
Clean Coalition reply comments on guiding principles for the Net Energy Metering (NEM) proceeding center around the need for a greater focus on sustainable growth of NEM projects in underserved communities, including promoting energy storage. We also request that the guidelines ensure that evaluation of NEM projects be based on the net benefits to the entire electrical system, not just the distribution system.
CPUC: Joint Assigned Commissioner’s Scoping Memo and Administrative Law Judge Ruling Directing Comments on Proposed Guiding Principles Related to Net Energy Metering | 4 December 2020
In opening comments, the Clean Coalition requests the inclusion of phrases in two guiding principles that will focus the proceeding on the impacts NEM has on the distribution and transmission systems and to ensure that the successor tariff will enable electrification in alignment with state policy. We also request the removal of the word “continue” from a third guideline to guarantee that the proceeding is not limited in discussions about solutions promoting equitable growth of renewable resources in all communities, especially low-income and disadvantaged communities.
CPUC: E-mail Ruling Introducing Distributed Energy Resources Tariff Staff Proposal and Directing Comments and Responses to Questions — reply comments | 11 November 2020
Clean Coalition reply comments center around refuting claims by Cal Advocates, SDG&E, and PG&E about the recklessness of including an over-procurement margin (since not all of the generation of a DER project will be used for deferral purposes), the utility preference that each IOU only be required to administer one of two deferral programs, and the opinion that DER aggregation is not yet commercially feasible.
CPUC: E-mail Ruling Introducing Distributed Energy Resources Tariff Staff Proposal and Directing Comments and Responses to Questions | 11 November 2020
In opening comments, the Clean Coalition commends the creation of a tariff that will allow utilities to leverage a combination of front-of-meter (FOM) and behind-the-meter (BTM) DER to defer the need for infrastructure upgrades on the distribution system. We argue that utilizing multiple sources of capital — including existing programs and private capital — will allow for the most efficient aggregations of projects to be deployed. Clean Coalition comments also suggest the need to properly assess Transmission Access Charges and advocate for a Feed-In Tariff as an ideal DER procurement mechanism.
CPUC: Presentation on Clean Coalition Proposal 19d in Rule 21 Working Group 4 | 16 October 2020
The Clean Coalition advocates for Proposal 19d, requiring the use of template single-line diagrams for Zero Net Energy Facilities. When a utility has 50 applications in a project category (e.g., NEM-paired storage, Rule 21 non-NEM export, Rule 21 grid services, etc.), they will be required to have a call with stakeholders within 90 days and publish the template diagram within 120 days of the stakeholder engagement. The proposal does not inhibit the utility review process or require duplicative efforts.
CPUC: Policy Questions on an Interim Approach for Minimizing Emissions from Generation during Transmission Outages — reply comments | 2 October 2020
The Clean Coalition supports proposals by Tesla and Sunrun to use solar microgrids for substation-level backup power and questions why their initial proposals were rejected by the Commission. Our comments also push back on PG&E’s assertion that diesel should be phased out over the next 7 years and requests that PG&E explain why existing proposals are not sufficient to proceed to an RFP.
CPUC: Rulemaking to Investigate and Design Clean Energy Financing Options for Electricity and Natural Gas Customers | 30 September 2020
The Clean Coalition advocates for the need to determine a standard value-of-resilience and suggests the Dispatchable Energy Capacity Services (DECS) market mechanism as two important value adders for electrification. Comments conclude by proposing our Electrification & Community Microgrid Ready (ECMR) guidelines as a way to transparently promote the standard costs associated with electrifying a facility in preparation for interconnection to a Community Microgrid.
CPUC: Order Instituting Rulemaking on Net Energy Metering Successor Tariff | 28 September 2020
The Clean Coalition’s comments suggest switching to inverter-based restrictions rather than generation-based restrictions and highlight the need to amend NEM to allow facilities with plans to electrify in the near term to oversize generation. For resilience purposes, the Clean Coalition calls for the removal of energy storage sizing limits.
CPUC: Policy Questions on an Interim Approach for Minimizing Emissions from Generation during Transmission Outages | 25 September 2020
The Clean Coalition lambasts the Commission for waiting to take action on the issue of substation backup power until August 2020, defaulting to the use of diesel fuel for 2021 after explicitly stating only three months earlier that it would only be acceptable for use in 2020. Instead of diesel fuel as a primary energy source, Solar Microgrids should be installed with diesel fuel as a secondary backup, to be disconnected as more PV resources are aggregated. Solar+storage resources provide everyday power and grid services that fossil fuel resources cannot, making them much more cost-effective in the long term.
CPUC: Proposed Decision Resuming and Modifying ReMAT — reply comments | 15 September 2020
The Clean Coalition reply to party comments supports the need for determining avoided cost using similar-sized RPS contracts, time-of-delivery factors, as well as adders for the value of resilience and locational pricing. Comments also specify the need for creating standards for co-located storage and explain why the use of price adjusting mechanisms is more effective than administratively set prices.
CPUC: Proposed Decision Adopting Recommendations from Working Groups Two, Three, and Subgroup — reply comments | 14 September 2020
Clean Coalition reply comments are in alignment with Tesla and CALSSA on a multitude of issues, including the need to lower standard fees to the level of NEM projects, the importance of designating one point person for each interconnection application, and a request that the Commission clarify the decision to remove the size limit for Fast Track eligibility. The Clean Coalition agrees that changing the size limit will only be effective if projects are eligible regardless of the available hosting capacity.
CPUC: Proposed Decision Resuming and Modifying ReMAT | 10 September 2020
Clean Coalition comments decry the Proposed Decision for refusing to consider any party proposals and suggest that at best, the Proposed Decision leaves the door open for the creation of an optimal successor Feed-In Tariff (FIT). Comments include reasons why the Commission must consider properly assessing Transmission Access Charges (TAC) for ReMAT projects and should include adders for resilience and locational pricing. Moreover, the Clean Coalition lambasts the Commission for using the explicit language of PURPA as an excuse not to innovate or logically create a tariff.
CPUC: Proposed Decision Adopting Recommendations from Working Groups Two, Three, and Subgroup | 9 September 2020
Clean Coalition comments support the Proposed Decision as helping to reduce the uncertainty in the interconnection process through the removal of the size limit for Fast Track eligibility and suggests that the Commission approve a proposal to lower upfront fees. The latter section focuses on reasons why the Commission should adopt a proposal to incorporate a GPI/Clean Coalition Roadmap to automation as a way to proactively address the issues the proceeding will need to consider in the next few years as well as a proposal to designate a point person at a utility for interconnection applications of projects over 100 kWA.
CPUC: Community Microgrid Enablement Program | 8 September 2020
The Clean Coalition response supports PG&E’s Community Microgrid Enablement Program, lauding PG&E for taking a role as a community partner to deploy Community Microgrids. The program creates a framework that allows communities to identify their resilience needs, promoting the inclusion of as many customers as possible that can be supplied with 20 MW of renewable resources. The filing concludes with a few Clean Coalition recommendations to increase transparency for the benefit of local governments.
CPUC: Microgrid Track 2 — reply comments | 28 August 2020
Parties, including the Clean Coalition, consider the lack of focus in Track 2 on Community Microgrids and the need for a full microgrid compensation tariff to consider normal instances when a microgrid is not in an islanded mode. Comments strongly address the conservative nature of the proposals in the Staff Proposal, lambasting the Commission for slowing the pace of progress by delaying the definition for a value of resilience and failing to value the public benefit it provides.
CPUC: Distribution Resources Planning IComp AFR | 24 August 2020
The Clean Coalition argues that the Commission is violating the spirit of the Intervenor Compensation program by only focusing on customer status, refusing to consider the Clean Coalition’s substantial contributions to the proceeding. Doing so limits the participation of groups like the Clean Coalition, thus overstating the positions of the utilities, who prioritize rates of return. Second, the Clean Coalition argues that with California’s clean energy goals, the entire state is aligned with the renewable energy industry; since the Clean Coalition has always focused on distribution-level renewable resources and resilience, it should not be discounted from customer status.
CPUC: Microgrid Track 2 comments | 14 August 2020
The Clean Coalition comments focus on criticizing the Staff Proposal for the lack of a standard microgrid tariff, including any type of discussion on resilience and the Value of Resilience. Before getting to the Staff Proposal, the comments note the complete absence of logic in choosing to include a detailed concept paper and then not allow any comments on the Concept Paper into the record for Track 2. For the five proposals, the Clean Coalition supports ambitious positions that enable Community Microgrids and Feed-In Tariff-like pilot programs rather than the Commission’s typical conservative steps that kick the can further down the road.
CEC: IEPR comments | 30 July 2020
In this comment letter, the Clean Coalition advocates that the California Energy Commission (CEC) develop a Community Microgrid pilot in a comprehensive grid area or on a substantial feeder (containing critical facilities). A CEC-sponsored Community Microgrid pilot will run in parallel with the California Public Utilities Commission (CPUC) microgrid proceeding, forcing the CPUC to consider current market distortions, including the assessment of Transmission Access Charges and the lack of a standard value-of-resilience. The Clean Coalition offers the Goleta Load Pocket as an ideal location for the siting of a Community Microgrid pilot.
CPUC: ReMAT ruling — reply comments | 28 July 2020
In reply comments, the Clean Coalition aligns with other parties about the need to deny the Staff Proposal in favor of a two-track proceeding to temporarily apply the Renewable Market Adjusting Tariff (ReMAT) program with modifications and to create the ideal ReMAT program by the end of 2021. Comments also focus on considering existing Petitions for Modification (the Clean Coalition has two), the importance of considering co-located storage, and denying the IOU Proposal, which calls for pricing ReMAT contracts on all resources (e.g., fosil-fuel generation, not just RPS prices).
CPUC: Resuming and updating ReMAT — reply comments | 21 July 2020
This filing represents the Clean Coalition’s reply comments on the Renewable Market Adjusting Tariff (ReMAT) ALJ Ruling and Staff Proposal. The Clean Coalition comments take the approach that the Staff Proposal must be denied since the administratively set prices are based on skewed data from larger RPS contracts that are over two years old, and do not represent a true cost of energy since they do not consider Transmission Access Charges or a value of resilience. Instead, ReMAT must be temporarily applied with the fewest possible changes to allow projects waiting in the interconnection queue to begin procuring, and then an ideal successor tariff must be created based on the Feed-In Tariff the Clean Coalition designed for the City of San Diego.
CEC: Solar+storage is superior to diesel generators for backup power at Microsoft data center | 21 July 2020
In this filing, the Clean Coalition urges the California Energy Commission (CEC) to consider solar+storage primarily, along with other suitable renewable alternatives, to determine how many of the 40 (3 MW) diesel generators could be replaced in Microsoft’s proposed data center project in San Jose, CA. The current proposal does not consider anything beyond diesel generators, which, if installed, will pollute a low-income and disadvantaged community in San Jose.
FERC: Urgency in addressing Transmission Access Charges when valuing DER | 15 June 2020
This filing represents the Clean Coalition’s comments urging the Federal Energy Regulatory Commission (FERC) to deny a petition that constitutes federal overreach into an issue that must be left to the states. The petition would allow FERC to regulate any excess NEM energy sold to the utility as soon as it leaves the customer meter, which is a mistake considering that almost zero excess energy ever reaches the wholesale market (or uses the transmission system). We submit that approving the petition would further depress the true value of DER, which is why FERC would be better off denying the petition and considering addressing Transmission Access Charges.
CPUC: Intervenor compensation eligibility | 12 June 2020
This filing represents the Clean Coalition’s comments opposing a CPUC Proposed Decision that would find us ineligible for intervenor compensation for participation in this CPUC proceeding, with implications for other proceedings. A finding was made in R.15-02-020 that mischaracterized the work of the Clean Coalition as a market participant rather than an environmental ratepayer advocate, negatively impacting eligibility for compensation for substantial contributions made in CPUC decisions. We argue that the finding erred both legally and factually.
CARB: Advanced Clean Truck regulation support letter | 28 May 2020
In this letter to the California Air Resources Board (CARB), the Clean Coalition applauds the Board for considering a more stringent Advanced Clean Truck rule and urges them to affirm the new rule, with the modification that it be reconsidered in three years (rather than five). We also argue that the rule should apply to all medium and heavy class trucks and request that the definition of “large fleet” be changed from 100 or greater to anything over 50.
CPUC: Microgrids and strategies for valuing resilience – reply comments | 26 May 2020
This filing represents the Clean Coalition’s support of requests from other parties, primarily related to issues surrounding utility transparency with the CPUC and other stakeholders, for assurances that fossil fuel generation is temporary and will be transitioned into renewable resources, including proposals to expedite microgrid interconnection.
CPUC: Microgrids and strategies for valuing resilience | 19 May 2020
This filing represents the Clean Coalition’s argument that PG&E (or any other IOU) installing natural gas generation for resilience should be required to submit a plan detailing a transition to DER and solar+storage microgrids within five years. We promote proposals to expedite interconnection, although we lambast the CPUC’s lack of interest in smart metering. The Clean Coalition also applauds decisions to remove energy storage sizing limits, though we request that the CPUC requires islanding — either in this track or in track 2. Our comments also focus on ensuring that this Proposed Decision promotes progress, not more of the business-as-usual approach by utilities and policymakers; to that end, we request that the Proposed Decision is modified to ensure that the CPUC considers key details (like the value of resilience) and promotes transparency in information sharing between IOUs and key stakeholders.
CPUC: Resuming ReMAT under PURPA | 28 April 2020
This filing represents comments filed by joint parties including the Clean Coalition, public agencies, and private energy firms supporting the proposed expansion of PURPA small renewable energy contract terms and necessary contract lengths to support financing. We additionally emphasize the importance of avoiding a delay in the adoption of PURPA terms in order to allow the associated Renewable Market Adjusting Tariff (ReMAT) procurement program to resume.
CPUC: DER Avoided Cost Calculator and transmission – reply comments | 7 April 2020
This filing represents the Clean Coalition’s reply comments on the proposed decision modifying the DER Avoided Cost Calculator. We reinforce the need for correction of the transmission value of DER in the calculator used across CPUC proceedings. We note agreement from multiple parties in opening comments for both the immediate adoption of interim methodologies and a full refinement before the end of 2020. We also rebut assertions that DER does not mitigate all drivers of transmission investment, detailing examples and expanding upon our opening comments.
CPUC: DER Avoided Cost Calculator and transmission | 2 April 2020
This filing represents the Clean Coalition’s comments on the proposed decision modifying the DER Avoided Cost Calculator. We largely support the proposal with the exception of the transmission valuation. Expressing the true value of transmission costs that can be avoided through the use of DER and microgrids is a critical component of the cost-effectiveness of any sort of DER project, program, or policy. We provide examples of billions of dollars of actual DER-driven avoided annual transmission costs, and argue that the Avoided Cost Calculator must reflect these savings.
CPUC: Proper valuation of DER | 26 February 2020
This filing represents the Clean Coalition’s comments on the CPUC’s Decision Adopting Staff Proposal on Avoided Costs and Locational Granularity of Transmission and Distribution Deferral Values, in which we dispute staff conclusions of negligible value of DER and call for a schedule for consistent valuation across utilities based on the record of factual data.
CPUC: Proving microgrid resilience benefits – reply comments |6 February 2020
This filing represents the Clean Coalition’s reply to the staff and investor-owned utility (IOU) proposals on short-term resilience strategies. The Clean Coalition’s comments prioritize holding the IOUs accountable by tracking the total cost of fossil-fuel generation (proving that renewables-driven microgrids are a more effective solution), sharing information with local agencies, annual verification reports, and pushing for a more widespread deployment of smart meters with islanding capabilities across IOU service territory.
CPUC: Proving microgrid resilience benefits | 30 January 2020
This filing represents the Clean Coalition’s reply to the CPUC administrative law judge’s questions about the staff and investor-owned utility proposals for microgrid resilience strategies. Our comments lambast the potential use of fossil-fuel generation near substations and prioritize DER generation, along with an increase in grid isolation switches, and we illustrate effective use of data sources to map priority microgrid siting. The Southern California Edison proposal includes a portion in Montecito, so our comments use the Montecito Community Microgrid Initiative and greater Goleta Load Pocket area to demonstrate the resilience that a true Community Microgrid can bring and a few of the policies inhibiting them from being built.
CPUC: Improving construction timelines and more under Rule 21 – reply comments | 27 January 2020
This filing represents the Clean Coalition’s reply comments on the CPUC’s administrative law judge’s questions following the submission of proposals for improving interconnection in the Rule 21 Working Group 3 Final Report and workshop presentations. In reply, the Clean Coalition focuses on correction of Cost of Ownership grid upgrade cost allocations improperly burdening new distributed renewables, as well as other issues.
CPUC: Improving construction timelines and more under Rule 21 | 13 January 2020
This filing represents the CPUC’s administrative law judge’s questions following the submission of proposals for improving interconnection in the Rule 21 Working Group 3 Final Report and workshop presentations. The Clean Coalition focuses on those questions related to our proposals regarding use of non-utility contractors to improve construction timelines and correction of Cost of Ownership grid upgrade cost allocations improperly burdening new distributed renewables, as well as other issues.
CPUC: The Avoided Cost Calculator and avoided transmission value | December 30, 2019
This filing represents the Clean Coalition’s support for the staff proposal (with the exception of the transmission valuation) that the Avoided Cost Calculator (ACC) needs to adopt an avoided transmission value pending future refinement in the DRP proceeding. Expressing the true value of transmission costs that can be avoided through the use of DER is a critical component of the cost-effectiveness of any sort of DER project, program, or policy. We provide examples of billions of dollars of actual DER driven avoided annual transmission costs, and argue that the ACC must reflect these savings.
CPUC: Streamlining interconnection in 2019 | December 24, 2019
The Clean Coalition submitted comments on the policy mechanisms needed to streamline interconnection via the Clean Coalition’s WDG Streamlined Interconnection Pilot and an Interconnection Roadmap for Automation written by Sahm White and Tam Hunt of the Green Power Institute. The comments mentioned interconnection difficulties experienced during the VGES interconnection process as well as the interconnection case study currently being prepared. The comments end with a short reply on the other proposals presented at the forum
CEC: Climate adaptation and the Clean Coalition’s work | November 27, 2019
This filing represents the Clean Coalition’s comments on the CEC’s Integrated Energy Policy Report Workshop on Climate Adaptation. The Clean Coalition appreciates the focus on supporting microgrids with distributed energy resources (DER) for critical facilities and believes it is crucial for the IEPR to consider measures needed to proliferate Community Microgrids in California. This proliferation can be ensured by reforming the way Transmission Access Charges (TAC) are assessed, divesting the IOUs of their transmission assets, streamlining interconnection for wholesale distributed generation (WDG), establishing effective procurement methods like a market-responsive Feed-In Tariff (FIT), and standardizing a Value of Resilience for all electric loads (VOR123).
CPUC: Extended Day Ahead Markets and Transmission Access Charges | November 22, 2019
This filing represents the Clean Coalition’s comments on the issue paper in the CAISO stakeholder process on Extended Day Ahead Markets (EDAM). Our recommendations focused on reforming Transmission Access Charges (TAC) so they are measured at transmission distribution stations rather than at individual customer meters. Implementing this solution in coordination with the CPUC would promote the deployment of Distributed Energy Resources (DER) for EDAM, saving 3 cents per kilowatt on local clean energy projects and reducing the need for transmission infrastructure expansion.
CPUC: Valuing resilience with Community Microgrids – reply comments | November 4, 2019
This filing represents the Clean Coalition’s reply comments on the opening comments made by 36 parties about the Preliminary Scoping Document for Rulemaking 19-09-009. The Clean Coalition called for a focus on Community Microgrids and focused on comments by parties explaining that they are an important alternative to expanding the transmission system for the sake of grid hardening and provide both baseload and backup power for a community. We recommended that based on the consensus about the importance of Community Microgrids as a resilient solution, an essential part of this proceeding must be to create a standard value of resilience. These comments were made regarding California Microgrid Bill SB 1339.
CPUC: Valuing resilience with Community Microgrids | October 21, 2019
This filing represents the Clean Coalition’s opening comments advising the CPUC to focus the upcoming proceeding on Community Microgrids, with a focus on the Goleta Load Pocket as the ideal location for a pilot program. We recommended the CPUC properly value resilience by using VOR123 as well as implementing a Feed-In Tariff mechanism, with Market Responsive Pricing and a Dispatchability Adder (DECS), to streamline the procurement of renewable resources for Community Microgrids. These comments were made on the Order Instituting Rulemaking (OIR) Regarding Microgrids Pursuant to SB 1339.
CPUC: Reopening ReMAT and supporting pending projects | August 13, 2019
This filing represents the Clean Coalition’s joint party letter in response to the Appleate Court ruling upholding a stay on the CPUC’s renewable energy market adjusting tariff (ReMAT) due to the failure to also offer PURPA compliant alternatives. We offered legal analysis to make it clear that there is no actual injunction against ReMAT and that pending projects should be allowed to contract without further delay following approval of the draft Proposed Decision.
CPUC: ICA maps and groundbreaking transparency into the California’s energy distribution system | August 1, 2019
This filing represents the Clean Coalition’s opening comments on refinements to the newly implemented Interconnection Capacity Assessment (ICA) maps and data access to improve their user functionality and continue development of this groundbreaking transparency into the California’s energy distribution system. While continuing to support the long term recommendations of the ICA working group in which we were a leading participant, we drew attention to issues with the initial statewide implementation. We also further promoted the use cases for the ICA beyond the interconnection process itself, addressing its important role in planning appropriately targeted local distribution investment and assessing the impact of policy options.
CPUC: Urging reinstatement of ReMAT | August 1, 2019
Ths filing represents a joint party letter in response to the Appleate Court ruling upholding a stay on the CPUC’s renewable energy market adjusting tariff (ReMAT) due to the failure to also offer PURPA compliant alternatives. The Clean Coalition urged the CPUC to promptly approve the PURPA options in the December 2018 settlement proposal and re-instate the ReMAT program without delay.
CPUC: Comments on Interconnection Practices and Distribution Resources Planning maps | July 17, 2019
This filing represents the Clean Coalition and Green Power Institute’s joint informal comments offering written feedback following the initial stakeholder meeting on publication of ongoing deployment data. The Clean Coalition strongly supports the framework currently utilized for CSI and NEM data with the addition of greater granularity by size, technology and location, and alignment with related Distribution Resources Planning maps (ICA, LNBA and GNA).
CPUC: Comments on the Interconnection Practices Evaluation Research Plan | July 10, 2019
This filing represents the Clean Coalition and Green Power Institute’s joint comments offering written feedback following the initial stakeholder meeting on the proposed Interconnection Practices Evaluation Research Plan. The Clean Coalition strongly supports the initiative, but calls for more extensive research questions, data development, and outreach covering all applications of 100 kW and above, and analysis of results prior to initial development of recommendations.
CPUC: Methodologies for calculating avoided distribution and transmission costs attributable to DER growth | June 21, 2019
This filing represents the Clean Coalition’s brief comments on the white paper prepared by the CPUC’s Energy Division related to methodologies for calculating avoided distribution and transmission costs attributable to DER growth in the Avoided Cost Calculator, Locational Net Benefits Assessment, and associated proceedings. While we support the distribution level methods, the estimated results at the transmission level are far below actual reported. We submitted evidence and cited examples of actual transmission savings and methodological factors for further consideration.
CPUC: Procuring energy storage with a FIT approach and market responsive pricing| March 9, 2019
This filing represents the Clean Coalition’s proposal to amend the Proposed Decision modifying the applications by SDG&E, PG&E, and SCE regarding procurement of new energy storage in compliance with AB 2868. We broadly support the PD but oppose the use of an RFO bidding procurement process and recommend use of a FIT approach with Market Responsive Pricing. This avoids the costly barriers to participation inherent in RFO bidding, which is inappropriate for distributed resource procurement. A FIT will result in greater market participation and lower costs for ratepayers.
CPUC: Appropriate allocation in interconnection | February 22, 2019
This filing represents the Clean Coalition’s review and reply to opening responses to the CPUC ALJ’s questions regarding the Final Report of Working Group 2 on Interconnection Streamlining. Our brief comments focus on the issues raised regarding assessment of costs and benefits of investment in improvements in interconnection processes and appropriate allocation.
CPUC: Intervenor compensation arguments | February 21, 2019
This filing represents the Clean Coalition’s comments opposing CPUC Commisioner Randolf’s Alternate Proposed Decision which would find us ineligible for intervenor compensation for participation in this CPUC proceeding, with implications for other proceedings. A finding was made in R.15-02-020 that mischaracterized the work of the Clean Coalition as a market participant rather than an environmental ratepayer advocate, negatively impacting eligibility for compensation for substantial contributions made in Commission Decisions. We argue that the finding errored both legally and factually and the Commission adopt the earlier Proposed Decision of Administrative Law Judge Hymes awarding compensation. The ex parte letter to the CPUC is located here.
CPUC: Reopening the ReMAT program in California | February 20, 2019
This filing represents a joint letter to CPUC commissioners urging the CPUC to proceed with adopting the PURPA Proposed Decision to enable the ReMAT program to be reopened without delay and proceed with approved procurement of the remaining 200 MW of capacity.
CPUC: Threats against the Green Tariff Shared Renewables program | February 8, 2019
This filing represents the Clean Coalition’s response related to Southern California Edison’s application to terminate the Green Tariff Shared Renewables program and replace it with five proposed Green Energy Programs. We argue that a Feed-in Tariff can be implemented consistent with Senate Bill 43 and is a better alternative.
CPUC: Final report on interconnection streamlining | February 1, 2019
This filing represents the Clean Coalition’s responses to the CPUC administrative law judge’s questions regarding the Final Report of Working Group 2 on interconnection streamlining, with a major focus on integration of newly available ICA hosting capacity results into the interconnection application review process and tariff, and other process and automation improvements.
CPUC: Opposing restricted access to PV RAM maps with IREC, SEIA, CSSA, and Vote Solar | January 9, 2019
This filing represents joint comments with the Interstate Renewable Energy Council (IREC), Solar Energy Industries Association (SEIA), California Solar & Storage Association (CSSA), California Community Choice Association, and Vote Solar to oppose the investor-owned utility Petition for Modification to restrict access to exising PV Renewable Auction Mechanism (RAM) interconnection maps and application of a non-disclosure agreement. We argue that utilities have not shown cause and note established compliance with prior rulings requiring publication, including the recent Ruling (R.14-08-013 Dec. 17, 2018) denying identical utility action related to the new Interconnection Capacity Analysis hosting capacity maps.
CPUC: Joint letter on Resource Adequacy Proposed Decision | January 3, 2019
This filing represents a joint letter to California Public Utilities Commission (CPUC) Commissioners urging the rejection the Proposed Decision issued November 21, 2018 regarding Resource Adequacy (RA) which puts investor-owned utilities (IOUs) in an exclusive central buyer role for local RA and allows IOUs to recover RA costs through non-bypassable charges. Most parties agree that a “residual” rather than “full” central buyer model is the better choice.
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