Slouching toward a microgrid tariff in California
In an op-ed for Energy Central, Communications Director Rosana Francescato discusses what it will take to fulfill SB 1339’s promise of commercializing microgrids across the state.Read article
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.
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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