Regulatory filings 2008 - 2018

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 officially submitted in the years 2008 – 2018. For more recent filings, see this page.

2018

CPUC: Application for rehearing of Decision 18-11-010 | December 19, 2018
This filing represents an application by the Clean Coalition to request a rehearing of a denial of eligibility for compensation for participation in CPUC proceeding R.15-02-020, with implications for other proceedings. A finding was made in November 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.

CPUC: Joint filing with Vote Solar, Tesla, and more on ICA map confidentiality – 3rd follow-up report | December 14, 2018
This filing represents a follow-up report from a joint filing with Vote Solar, Tesla, and others regarding the development and application of a non-disclosure agreement for access to confidential or redacted information associated with grid maps for Interconnection Capacity Analysis (ICA) hosting capacity, grid needs assessments, and Locational Net Benefits Analysis. The joint parties maintain that, while there may be a need for confidentiality with respect to narrowly defined, site-specific information about facilities shown to meet the definition of critical energy infrastructure, to date the utilities have failed to identify any such information.

CPUC: Rule 21 interconnection issue updates | December 3, 2018
This filing represents the Clean Coalition’s responses to questions raised in the Revised Scoping Memo for the current Rule 21 interconnection proceeding, focusing on the most effective processes for resolution of issues, including technical working groups, formal written comments and testimony, or informal discussion forums led by California Public Utilities Commission (CPUC) staff.

CPUC: Joint filing with Vote Solar, Tesla, and more on ICA map confidentiality – follow-up report | November 30, 2018
This filing represents a follow-up report from a joint filing with Vote Solar, Tesla, and others regarding the development and application of a non-disclosure agreement for access to confidential or redacted information associated with grid maps for Interconnection Capacity Analysis (ICA) hosting capacity, grid needs assessments, and Locational Net Benefits Analysis. The joint parties maintain that, while there may be a need for confidentiality with respect to narrowly defined, site-specific information about facilities shown to meet the definition of critical energy infrastructure, to date the utilities have failed to identify any such information.

CPUC: Joint settlement to address fixed price contracts – reply comments | November 28, 2018
This filing represents reply comments from a joint settlement proposal of investor-owned utility and qualifying facility (QF) parties, along with the Clean Coalition, for interim measures to address Public Utility Regulatory Policies Act (PURPA) requirements for fixed priced contracts. This proposal adopts and modifies existing QF settlement terms until the expiration of the QF settlement and adoption of new PURPA avoided cost terms in 2020.

CPUC: Joint filing with Vote Solar, Tesla, and more on ICA map confidentiality | November 16, 2018
This filing represents a joint filing with Vote Solar, Tesla, and others regarding the development and application of a non-disclosure agreement for access to confidential or redacted information associated with grid maps for Interconnection Capacity Analysis (ICA) hosting capacity, grid needs assessments, and Locational Net Benefits Analysis. The joint parties maintain that, while there may be a need for confidentiality with respect to narrowly defined, site-specific information about facilities shown to meet the definition of critical energy infrastructure, to date the utilities have failed to identify any such information.

CPUC: Joint settlement to address fixed price contracts | November 14, 2018
This filing represents a joint settlement proposal of investor-owned utility and qualifying facility (QF) parties, along with the Clean Coalition, for interim measures to address Public Utility Regulatory Policies Act (PURPA) requirements for fixed priced contracts. This proposal adopts and modifies existing QF settlement terms until the expiration of the QF settlement and adoption of new PURPA avoided cost terms in 2020.

CPUC: PG&E compliance to restore access to interconnection maps | October 16, 2018
This filing represents the Clean Coalition’s protest of Pacific Gas & Electric’s (PG&E) motion and failure to comply with our requested ruling to restore access to the PV Renewable Auction Mechanism (RAM) interconnection maps pending release of the delayed new interconnection capacity assessment (ICA) maps. PG&E filed a motion requesting a three week extension to comply, and then complied the next day.

CPUC: Rule 21 interconnection capacity assessment and published hosting capacity | October 15, 2018
This filing represents the Clean Coalition’s drafted and filed the Final Status Report for the Rule 21 interconnection Working Group 2, summarizing the progress in development of final proposals on all scoped issues, with primary focus on the use of interconnection capacity assessment (ICA) published hosting capacity values in the actual project application review process.

CAISO: Transmission Access Charge Structure Enhancements: Draft Final Proposal | October 9, 2018
This template has been created for submission of stakeholder comments on the TAC Structure Enhancements: Draft Final Proposal that was published on September 17, 2018. The TAC Structure Enhancements, Stakeholder Meeting presentation, and other information related to this initiative may be found on the initiative webpage at: http://www.caiso.com/informed/Pages/StakeholderProcesses/TransmissionAccessChar geStructureEnhancements.aspx.

CPUC: Rule 21 motion on scheduling and processes | October 8, 2018
This filing represents the Clean Coalition’s response to investor-owned utilities’ (IOU) motion to change schedules and processes by which 20 scoped issues are to be addressed. The Clean Coalition supports allowing additional time and recommends moving less urgent issues to the second half of 2019, however we oppose IOU proposals to address topics only through written comments without Rule 21 Working Group efforts to refine or resolve issues.

CPUC: Exempting DER projects from transmission study reviews | September 12, 2018
This filing represents the Clean Coalition’s reply comments on California Public Utilities Commission (CPUC) Administrative Law Judge questions from the Rule 21 Working Group 1’s report supporting the exemption from transmission study reviews for distributed energy resource (DER) projects regardless of their net enery metering (NEM) eligibility.

CPUC: Extending Distribution Planning Advisory Group review of DER solicitations | September 11, 2018
This filing represents the Clean Coalition’s comments supporting the California Public Utilities Commission’s (CPUC) ruling extending the Distribution Planning Advisory Group review to provide a preliminary evaluation of recent distributed energy resource (DER) solicitations to inform investor-owned utilities’ process, understand how planning assumptions influence both the reported grid needs and define the contingency requirements, and contribute to related active developments in the Integrated Distributed Energy Resources Rulemaking.

CPUC: Comments addressing revised Moorpark Subarea solar+storage procurement plan | September 7, 2018
This filing repreents the Clean Coation’s comments on the Revised Moorpark Sub-Area Procurement Plan. They address: applicability energy storage and demand response for Resouce Adequacy qualification and methodology, weaknesses in the Request for Offer procurement process, and a preferred alternative procurement process through standard offer market adjusting Feed-In tariffs and CLEAN programs.

CPUC: Establishing an intervenor compensation standard | August 10, 2018
This filing represents the Clean Coalition’s ex parte letter seeking to establish a workable Intervenor Compensation eligility standard for evaluating the customer status of organizations that recognizes the critical nature of customer interest demonstration projects by customer representative organizations. Demonstration projects are a powerful tool in customer advocacy, but current policy discourages such demonstration projects. We proposed that the CPUC adopt a policy that demonstration projects for the purpose of advancing customer interests be presumed to be consistent with customer interests.

CAISO: Second straw proposal on Transmission Access Charges (TAC) – revised | July 18, 2018
This filing repreesents the Clean Coalition’s revised comments on the California Independent System Operator’s (CAISO) second straw proposal to point out inconsistencies between CAISO’s rate design principles and cost allocations, as well as between the rationales for rejecting using Transmission Energy Downflow as the basis for Transmission Access Charges (TAC) and its rationales for adopting the hybrid structure of the TAC. Learn about the TAC Campaign here.

CPUC: Response to IOU Data Redaction Motions and avoiding distribution infrastructure investments | June 22, 2018
This filing represents the Clean Coalition’s response to investor-owned utility (IOU) Data Redaction Motions related to Grid Needs Assessments. We supported an interim common approach for all utilities with categorical criteria, case-by-case review, and refinements to maximize ratepayer savings through data access while ensuring restriction on sensitive security and market information, plus promoting the avoidance of distribution infrastructure investment.

California State Senate: Opposing Assembly Bill 813 on CAISO expansion | June 15, 2018
This letter represents the Clean Coalition’s opposition to California Assembly Bill (AB) 813. The proposed California Independent System Operator (CAISO) expansion would not deliver the promised benefits, and there are cheaper and more effective ways to address electric transmission issues. Using grid integration, energy storage, and better reserve and transmission rules are better approaches to integrate inflexible fossil fuel sources into the transition to the 100% renewable energy system. Given that reality, it is unconscionable to create massive regulatory and political risks by opening CAISO’s governance to an unaccountable regional board that gives disproportionate authority to coal and anti-renewable states. While AB 813 attempts to establish valuable standards for any regional transmission operator, these standards would be utterly unenforceable once CAISO is converted to an unaccountable regional transmission board.

CPUC: Supporting data leveraging DER for cost effective grid services and deferral of conventional grid investments | May 7, 2018
This filing represents the Clean Coalition’s protest of investor-owned utility proposals regarding the redaction of data to be published in association with distriubtion Grid Needs Assessments and Distribution Deferral Opportunities Reports. We argued that the proposed redaction of data did not comply with the Ordering Decision or goals of the California Public Utility Commission (CPUC) for data transparancy, supporting distributed energy resource (DER) opportunities to provide cost effective grid services and the deferral of conventional grid investments.

CAISO: Second straw proposal on Transmission Access Charges (TAC) | April 25, 2018
This filing repreesents the Clean Coalition’s comments on the California Independent System Operator’s (CAISO) second straw proposal to point out inconsistencies between CAISO’s rate design principles and its own proposal, as well as between the rationales for rejecting using Transmission Energy Downflow as the basis for Transmission Access Charges (TAC) and its rationales for adopting the hybrid structure of the TAC. Learn about the TAC Campaign here.

CPUC: Comments on greenhouse gas accounting methodology | April 20, 2018
This filing represents the Clean Coalition’s response to the California Public Utilities Commission’s (CPUC) call for comments on the greenhouse gas accounting methodology in the Integrated Resource Planning proceeding. We provided comments to further clarify the “Clean Net Short” methodology that was proposed by the CPUC. The Clean Coaltion advocated for clearer guidelines in accounting for wholesale distributed generation and better accounting methods for renewable energy credits.

CPUC: Joint comments with NRDC, EDF, and 350 supporting societal cost test | April 20, 2018
This filing represents joint comments submitted by the Clean Coalition, National Resources Defense Council (NRDC), Environmental Defense Fund (EDF), and 350 Bay Area on the Amended Proposal on Societal Cost Test in the California Public Utility Commission’s (CPUC) Integrated Distributed Energy Resources (IDER) proceeding. The comments argued in favor of immediate adoption of the SCT as the primary cost test, supported the greenhouse gas valuation methodology and improvements in related standard cost tests, but argued for the use of a lower discount rate and the inclusion of additional impact factor values.

CPUC: Rule 21 Working Group report | April 16, 2018
This filing summarizes the work of the Working Group in the Rule 21 proceeding regarding interconnection at the California Public Utilities Commission (CPUC). The Working Group recently released a report summarizing their efforts to better streamline the Rule 21 interconnection process for distributed energy resources (DER). In these comments, the Clean Coalition praised the work of the group, summarized our own efforts, and made a number of recommendations to improve the report.

CPUC: DER contribution to transmission planning | April 13, 2018
n reply to the Integrated Distributed Energy Resources (IDER) Amended Scoping memo comments, the Clean Coalition continued to advocate for consensus on including distributed energy resources (DER) conribution to transmission planning and credit for avoided transmission costs. Of particular importance in this filing was the treatment of tariffs in the development of DERs compared to a competitive solicitation which can be much more time consuming and complicated for bringing DERs on to the grid.

CPUC: Retooling utility business models | March 29, 2018
This filing lays out the Clean Coalition’s position on how business models for utilities should be retooled and also the theoretical justifications for the economics of CLEAN (Clean Local Energy Accessible Now) programs. We also urged further development of standard-offer contract, set-price tariff programs through the California Public Utilities Commission (CPUC).

CPUC: Supporting California’s grid modernization efforts | March 14, 2018
This filing represents the Clean Coalition’s comments in the California Public Utiltiies Commission (CPUC) Proceeding R.14-08-013, which addresses California’s grid modernization efforts. The Clean Coalition encouraged the CPUC to accelerate their deployment of distributed energy resources in order to maximize ratepayer benefits and to accelerate the development of a modern grid.

Colorado PUC: Modernizing Colorado’s grid with Distribution Resources Planning – reply comments | February 21, 2018
This filing represents the Clean Coalition’s reply comments in the Colorado Public Utilities Commission’s Proceeding 17M-0694E. These comments underscore points of alignment with other parties, rebut arguments against Distribution Resources Planning (DRP), and clarify the elements of robust Hosting Capacity Analysis.

CPUC: Supporting the extension of the Distribution Resources Plan proceeding | February 16, 2018
This filing represents the Clean Coalition’s comments on the Amended Scoping of the California Public Utilities Commission’s (CPUC) Distribution Resources Plan proceeding. Our comments support the refinements and extension of the proceeding, and favor the development of a Policy Scenario Analysis application and use case for the grid modeling capabilities developed in this proceeding.

CAISO: Widely supported sign-on letter calling for Transmission Access Charges (TAC) structural change | February 15, 2018
This filing represents the sign-on letter submitted by the Clean Coalition, 29 distributed energy resource developers, environmental groups, and energy experts calling for a change in the TAC structure to charge transmission use charges for energy using the transmission grid.

CAISO: Clean Coalition white paper on Transmission Access Charges (TAC) rate design | February 15, 2018
This filing represents the Clean Coalition’s extensive white paper outlining the specific cost-shifting impacts, relationship to cost-causation, legal requirements, and specific technical aspects of TAC rate design. Learn about the TAC Campaign here.

CAISO: First straw proposal on Transmission Access Charges (TAC) | February 15, 2018
This filing represents the Clean Coaltion’s comments addressing the concerns and issues raised by the California Independent System Operator (CAISO) with respect to its first straw proposal on the TAC structure. Learn about the TAC Campaign here.

CPUC: Saving the Green Tariff Shared Renewables program | February 2, 2018
This filing represents the Clean Coalition’s protest of Advice Letter (AL) 3722-E, which was filed by Southern California Edison (SCE) on December 22, 2017. The letter proposed the cancelation of the Green Tariff Shared Renewables program (GTSR). The GTSR program requires the state’s largest investor-owned utilities to offer renewable energy options to their customers. The program was established to expand access to renewable energy resources not only for industrial and commercial customers, but also for individual consumers. We urged the Commission to reject the AL and order SCE to continue the program. We recommend modifications to SCE’s program consistent with those proposed by Pacific Gas & Electric and San Diego Gas & Electric in their respective Advice Letters to address issues hindering the success of the GTSR program.

Colorado PUC: Modernizing Colorado’s grid with Distribution Resources Planning | January 31, 2018
This filing represents the Clean Coalition’s opening comments in the Colorado Public Utilities Commission’s Proceeding 17M-0694E. They focus on the importance of Distribution Resources Planning (DRP) and offer a set of draft DRP rules for the Commission’s consideration.

CAISO: Economic analysis demonstrating DER benefits in Southern California | January 17, 2018
This filing represents the Clean Coalition’s release of an economic analysis demonstrating that distributed energy resources (DER) can be considerably cheaper than long distance transmission, because DER produces valuable energy in addition to providing local energy reliability. Learn more about our solar+storage work in California’s Moorpark Subarea here.

CPUC: Procuring DER with a CLEAN FIT in Southern California | January 16, 2018
This filing represents the Clean Coalition’s rationale for using a CLEAN Feed-in Tariff (FIT) rather than a Request For Offer for all distrubted energy resource (DER) procurement in the Moorpark Subarea of Southern California. We also released an economic analysis demonstrating that DER can be considerably cheaper than transmission, because DER produces valuable energy in addition to providing local energy reliability. Learn more about our solar+storage work in California’s Moorpark Subarea here.

CPUC: Distribution Investment and Deferral Process – reply comments | January 16, 2018
This filing represents the Clean Coalition’s support of the proposed decision advancing Distribution Resources Planning, and specifically related to the forecasts of anticipated distributed energy resource development and the Distribution Investment and Deferral Process, and offers refinements in reply to party comments to ensure that the grid is prepared to realize and optimize the benefits available from this growth.

2017

CPUC: Retail energy choice under Distribution System Operators | November 28, 2017
This filing represents the Clean Coalition’s comments addressing some of the issues raised by highlighting the importance of a Distribution System Operator to manage a retail choice energy market, to act as a guarantor of services if private retailers fail, and to ensure reliability. We also addressed the suggestion of a fixed fee charge for transmission as a terrible idea that violates all principles of ratemaking and to suggest the California Public Utilities Commission (CPUC) open a proceeding to consider tranmission charges.

CPUC: Energy storage rules moving forward | November 28, 2017
This filing represents the Clean Coalition’s comments commending the California Public Utilities Commission (CPUC) on a solid decision moving forward rules to allow energy storage to participate in multiple markets. However, we also recommended that energy storage be allowed to recover payments for meeting multiple needs if the resource meets multiple needs, even if it is with a single activity. Also, we advocated for rules that allow distribution connected resources to participate in meeting behind-the-meter needs.

CPUC: Environmental Justice FIT for the Puente Power Project | November 3, 2017
This filing represents the Clean Coalition’s ex parte letter and Environmental Justice Feed-in Tariff (FIT) design proposal submitted to encourage the California Public Utilities Commission (CPUC) to adopt a FIT to handle alternative energy procurement for the Puente Power Project in the Moopark Subarea of southern California. More information can be found here. The ex party letter can be read here.

CEC: Proposing Feed-in Tariffs for Puente Power Project alternatives | October 19, 2017
This letter to the California Energy Commission (CEC) has the Clean Coalition highlighting the greater speed of Feed-in Tariffs (FIT) over Request for Offers when evaluating clean alternatives to the Puente Power Project in Southern California, which was recently rejected by the Commission.

CAISO: Transmission Access Charges (TAC) comments using the CAISO template | October 13, 2017
This filing represents the Clean Coalition’s official comments on our Transmission Access Charges (TAC) proposal based on the California Independent System Operator’s (CAISO) comment template on the last two stakeholder sessions. Learn about the TAC Campaign here.

CPUC: Ensuring that PG&E procures more clean energy | October 12, 2017
This filing represents the Clean Coalition’s protests of Pacific Gas & Electric’s (PG&E) request to end the procurement of sub-20 megawatt renewable projects under the RAM program. The Clean Coalition successfully argued to complete the approved procurement.

CAISO: Transmission Access Charges (TAC) estimating model underestimating future costs | September 27, 2017
This filing represents the Clean Coaliton’s brief comments to the California Independent System Operator (CAISO) regarding refinements to the model for forecasting future electric transmission costs and rate impacts. We noted that consideration of only approved projects will fail to account for projects that will be planned as new energy needs arise and therefore greatly underestimate future costs. Learn about the TAC Campaign here.

CPUC: Expediting interconnection dispute resolutions – reply comments | September 26, 2017
This filing represents the Clean Coalition’s reply comments in response to the draft resolution of California Public Utilities Commission (CPUC) Administrative Law Judge Michelle Cooke regarding adopting an expedited interconnection dispute resolution process as authorized by California Assembly Bill 2861. The final resolution largely adopted prior Clean Coalition recommendations to ensure that the scope, authority, and effectiveness of the dispute process and Rule 21 interconnection Working Group are effective. The Clean Coalition objected to the utilities’ request requiring that the interconnection process be halted during the dispute resolution process.

CPUC: Expediting interconnection dispute resolutions | September 21, 2017
This filing represents the Clean Coalition’s comments in response to the draft resolution of California Public Utilities Commission (CPUC) Administrative Law Judge Michelle Cooke regarding adopting an expedited interconnection dispute resolution process as authorized by California Assembly Bill 2861. The final resolution largely adopted prior Clean Coalition recommendations to ensure that the scope, authority, and effectiveness of the dispute process and Rule 21 interconnection Working Group are effective.

CPUC: Supporting the Proposed Decision on Interconnection Capacity Analysis and locational net benefits – reply comments | September 19, 2017
This filing represents the Clean Coalition’s reply comments on DRP (distribution resources planning) Track 1 supporting the Proposed Decision regarding the Interconnection Capacity Analysis (ICA) and Locational Net Benefits Assessment (LNBA), and offers additional support and recommmendations for their implementation. The Clean Coalition has been an active and consistent participant in both the California Public Utility Commission’s (CPUC) ICA and LNBA working groups and an original advocate for DRP and its processes. In addition, we have remained a leading intervenor in interconnection proceedings and an active participant in the Integrated Distributed Energy Resources working groups that seek to utilize the ICA and LNBA results. We commend the diligent efforts of working group members in addressing a large number of issues and reaching consensus to the full extent possible within the adjusted timeframe, and appreciate the work of the CPUC in reviewing and responding to the working group’s reports and recommendations. We broadly concur with and strongly support the Proposed Decision.

VA SCC: Recommendations for robust distribution grid planning in Virginia | September 15, 2017
This filing represents the Clean Coalition’s comments to the Virginia State Corporation Commission (VA SCC) on Dominion Energy Virginia’s Integrated Resource Plan proceeding, which recommends the adoption of a robust and proven distribution grid planning process. Distribution grid planning is fundamentally a planning process to bring transparency and public input into the development of resources within the distribution system, and to better enable the VA SCC to evaluate proposed utility investments based on cost-effectiveness for the state’s electricity consumers.

CPUC: Supporting the Proposed Decision on Interconnection Capacity Analysis and locational net benefits | September 14, 2017
This filing represents the Clean Coalition’s comments on Distribution Resources Plan Track 1 supporting the Proposed Decision regarding the Interconnection Capacity Analysis (ICA) and Locational Net Benefits Assessment (LNBA), and offers additional support and recommendations for their implementation. The Clean Coalition has been an active and consistent participant in both the California Public Utility Commission’s (CPUC) ICA and LNBA working groups and an original advocate for DRP and its processes. In addition, we have remained a leading intervenor in interconnection proceedings and an active participant in the Integrated Distributed Energy Resources working groups that seek to utilize the ICA and LNBA results. We commend the diligent efforts of working group members in addressing a large number of issues and reaching consensus to the full extent possible within the adjusted timeframe, and appreciate the work of the CPUC in reviewing and responding to the working group’s reports and recommendations. We broadly concur with and strongly support the Proposed Decision.

CPUC: Proposing a cost-effective solar+storage alternative to Puente gas plant (with supplemental testimony) | September 12, 2017
This filing represents the Clean Coalition’s testimonies modeling the costs of a solar+storage solution to replace the capacity provided by the Puente Power Project and the Ellwood Peaker plant. This was in response to a study by the California Independent System Operator (CAISO), which modeled distributed energy resource solutions to meet the capacity requirements in the Moorpark Subarea in the Santa Barbara region of California. CAISO’s model used battery storage only, binary on/off profiles of battery discharge, and outdated data, resulting in unrealistically high cost estimates. The Clean Coalition followed the same model used in the CAISO study, with up-to-date costs and improvements to the modeling of solar and energy storage dispatch. This testimony was submitted via the Center for Biological Diversity due to submissions requiring previously established party status. The Clean Coalition also submitted a letter summarizing the results of our Puente model and attached copies of the model and the testimony for submission to the CPUC. A second, supplemental testimony was given regarding battery operations and maintenance costs, and the costs of addressing battery degredation.

CPUC: Protesting IOU-proposed amendments to Rule 21 advanced inverter standards | September 6, 2017
This filing represents the Clean Coalition’s protests of the Advice Letters from Pacific Gas & Electric (PG&E), Southern California Edison (SCE), and San Diego Gas & Electric (SDGE) on proposed Rule 21 tariff amendments related to advanced inverter standards. While we strongly support both the deployment of advanced inverters and adoption of updated standards regarding their capabilities, the investor-owned utilities (IOUs) went beyond the recommendations of the Smart Inverter Working Group and attempted to imposed standards without review, and under language that could mean that the utilities would have the right to require services and communications to be provided without compensation even when they created direct costs for the owners.

CPUC: RPS procurement plans from the Load Serving Entities – reply comments | September 1, 2017
This filing represents the Clean Coalition’s reply comments in support of comments from the American Wind Energy Association California Caucus and the Large-scale Solar Association in favor of encouraging a steady market for distributed renewables and optimal usage of federal Production and Investment Tax Credits. Additionally, the Clean Coalition reiterated the importance of the transmission access charges (TAC) market distortion on distributed energy resources and urged the California Public Utiltities Commission to address that distortion in any approved Renewable Portfolio Standard (RPS) procurement.

CEC: Proposing a cost-effective solar+storage alternative to Puente gas plant | August 29, 2017
This filing represents the Clean Coalition’s testimony modeling the costs of a solar+storage solution to replace the capacity provided by the Puente Power Project and the Ellwood Peaker plant. This was in response to a study by the California Independent System Operator (CAISO), which modeled distributed energy resource solutions to meet the capacity requirements in the Moorpark Subarea in the Santa Barbara region of California. CAISO’s model used battery storage only, binary on/off profiles of battery discharge, and outdated data, resulting in unrealistically high cost estimates. The Clean Coalition followed the same model used in the CAISO study, with up-to-date costs and improvements to the modeling of solar and energy storage dispatch. This testimony was submitted via the Center for Biological Diversity due to submissions requiring previously established party status.

CPUC: Scoping DER interconnection issues under California Rule 21 – additional reply comments | August 25, 2017
This filing represents the Clean Coalition’s additional reply comments on the Order Instituting a Rulemaking for a new proceeding to address distributed energy resource (DER) interconnection issues pursuent to California Rule 21. An extension was granted due to multiple party comments not being available for review and reply at the time of the initial deadline. We resubmitted with additional comments on issues raised by Solar Energy Industries Association and the California Solar Energy Industries Association.

CPUC: Canceling planned PG&E procurement under RAM – reply comments | August 21, 2017
This filing represents the Clean Coalition’s reply comments in support of the Proposed Decision denying Pacific Gas & Electric’s (PG&E) Petion for Modification to cancel planned procurement under the Renewable Auction Mechanism (RAM) mechanism to procure renewable resources. We agree with the Decision, and note where opposing parties arguments are not germane to the purpose of RAM procurement.

CPUC: Rejecting Ellwood Peaker Plant refurbishment – solar+storage analysis | August 20, 2017
This filing represents the Clean Coalition’s letter to the California Public Utilities Commission (CPUC) with a model of the photovoltaic (PV) solar+storage alternative and costs analysis, demonstrating that PV solar+storage can meet the requirements of the Ellwood Peaker Project far more cost effectively.

CPUC: Supporting the Distribution Investment Deferral Framework | August 18, 2017
This filing represents the Clean Coalition’s response to party comments on the process for the Distribution Investment Deferral Framework (DIDF), especially to comments calling for abandoning the DIDF entirely. The Clean Coalition reiterated the facutal basis for the potential for distributed energy resources (DER) to meet distribution needs.

CPUC: Scoping DER interconnection issues under California Rule 21 – reply comments | August 14, 2017
This filing represents the Clean Coalition’s reply comments on the Order Instituting a Rulemaking for a new proceeding to address distributed energy resurces (DER) interconnection issues pursuent to California Rule 21. We strongly support renewed attention to both new and outstanding issues in this area.

CPUC: Canceling planned PG&E procurement under RAM | August 14, 2017
This filing represents the Clean Coalition’s comments in support of the Proposed Decision denying Pacific Gas & Electric’s (PG&E) Petition for Modification to cancel a planned procurement under the Renewable Auction Mechanism (RAM) mechanism to procure renewable resources. We agree with the Decision, which reflects our 2016 arguments in this proceeding, and recommend citing additional arguments as noted.

CPUC: Properly evaluating DER in distribution resources planning | August 7, 2017
This filing represents the Clean Coalition’s comments recommending that a revised framework for prioritizing distribution investments expressly evaluates their importance, urgency, and cost effectiveness. In addition, the criteria should not discriminate against distributed energy resources (DER).

CPUC: Social costs of greenhouse gases | August 3, 2017
This filing represents the Clean Coalition’s comments recommending that the proposed decision adopting an Interim Greenhouse Gas (GHG) Adder be amended to reflect that the chosen metric is not the most effective or accurate measure. Also, we supported the adoption of an interim GHG Adder and the numerical value selected.

CPUC: DER interconnection issues under Rule 21 | August 2, 2017
This filing represents the Clean Coalition’s comments on a new proceeding to address distributed energy resource (DER) interconnection issues pursuent to California Rule 21. We strongly support renewed attention to both new and outstanding issues in this area and recommended including several specific issues, such as: Clearly defined goals and direction, plus a “roadmap” for the future of interconnection; automation to support streamlining of processes and results; cost review; use of existing and planned facilities, plus associated cost responsibility; standardization of common charges based on categorical averages; and use of alternate approved providers for timely and more cost effective construction of required facility upgrades.

CAISO: Transmission Access Charges (TAC) structure review | July 26, 2017
This filing represents the Clean Coalition’s comments on the transmission access charges (TAC) structure in the recently launched “Review TAC Structure” stakeholder initiative at the California Independent System Operator (CAISO). In these comments, the Clean Coalition articulated its proposal to change the TAC billing determinant to the transmission energy downflow. This would result in more accurate market signals for the cost of delivering energy, the deployment of more distributed energy resources, and massive ratepayer savings in avoided transmission costs. Read more on the TAC Campaign here.

CPUC: High levels of DER and avoided transmission investments in Integrated Resource Planning – reply comments| July 12, 2017
This filing represents the Clean Coalition’s reply comments on the California Public Utilities Commission’s (CPUC) Staff Proposal on Implementing the Integrated Resource Planning (IRP) process. The Clean Coalition recommended that the development of a Reference System Plan as the model plan for all load-serving entities (LSE) consider a scenario with high levels of distributed energy resources (DER) and avoided transmission investments. In addition, the Clean Coalition pushed for full consideration of transmission costs as well as the energy services and avoided transmission costs of DER.

CPUC: DER growth forecast recommendations | July 10 2017
This filing represents the Clean Coalition’s recommendations that growth forecasts for distributed energy resources (DER) include forecasts of wholesale in front of the meter generation and storage, that the forecasts incorporate responses to new policies, and that forecasts incorporate a high DER use case to evaluate the impacts of underestimates in DER penetration.

CAISO: DER alternatives to avoid natural gas plants in Oxnard, CA | July 5, 2017
This filing represents the Clean Coalition’s comments urging the California Indepenedent System Operator (CAISO) to include a scenario of high penetration of solar+storage hybrid projects to meet the local capacity requirements for the Puente Power Project in Oxnard, CA. If CAISO adopts the proposal and adds the analysis to its report on distributed energy resources (DER) alternatives, the Clean Coalition anticipates CAISO will find definitively that these alternatives can feasibly meet the energy needs for the region.

CPUC: Interconnection dispute resolution – reply comments | June 30, 2017
This filing represents the Clean Coalition’s reply comments on the California Public Utility Commission’s (CPUC) Energy Division Staff Concept Paper for an expedited interconnection dispute resolution process, including the formation of a Rule 21 Working Group and the roles and activities of such an entitiy. These comments address utility comments regarding the scope and applicability of the Dispute Resolution Panel, eligibilty for application for Dispute Resolution, and prior requirements.

CPUC: RAM and sub-optimal grid conditions – reply comments | June 30, 2017
This filing repreents the Clean Coalition’s reply comments on the recent California Public Utility Commission (CPUC) Staff Proposal to use the Renewable Auction Mechanism (RAM) to procure renewable resources to address sub-optimal grid conditions and renewable curtailment. The Clean Coalition responded to comments clarifying that the RAM proposal compliments and does not duplicate previous efforts to procure distributed energy resources. The Clean Coalition also recommended that the CPUC continue to coordinate this proposal with other initiatives and activities, particularly for making use of existing cost-effectiveness and value assessment tools developed in other proceedings.

CPUC: High levels of DER and avoided transmission investments in Integrated Resource Planning | June 28, 2017
This filing represents the Clean Coalition’s comments on the California Public Utilities Commission’s (CPUC) Staff Proposal on Implementing the Integrated Resource Planning (IRP) process. The Clean Coalition recommended that the development of a Reference System Plan as the model plan for all load-serving entities (LSE) consider a scenario with high levels of distributed energy resources (DER) and avoided transmission investments. In addition, the Clean Coalition pushed for full consideration of transmission costs as well as the energy services and avoided transmission costs of DER.

CPUC: Utilities’ evolution into dedicated Distribution System Operators (DSO) | June 27, 2017
This filing represents the Clean Coalition’s comments following the California Public Utilities Commission (CPUC) Joint Agency Staff Workshop on Energy Roadmaps to introduce our proposal for the evolution of existing utilities into dedicated Distribution System Operators (DSO), establishing a clear demarcation between distribution and transmission operations and the management of market participation in support of the various Energy Roadmap goals.

CPUC: Interconnection dispute resolution | June 23, 2017
This filing represents the Clean Coalition’s comments on the California Public Utility Commission’s (CPUC) Energy Division Staff Concept Paper for an expedited interconnection dispute resolution process, including the formation of a Rule 21 Working Group and the roles and activities of such an entitiy.

CPUC: Grid modernization investments | June 19, 2017
This filing represents the Clean Coalition’s comments on the proposal for the grid modermization process for identifying investments, including making recommendations about recent policy proposals related to energy resources.

CPUC: RAM and sub-optimal grid conditions | June 19, 2017
This filing represents the Clean Coalition’s comments on the preliminary proposal to use the Renewable Auction Mechanism (RAM) to procure two projects in each investor-owned utility (IOU) service territory that would address sub-optimal grid conditions.

CPUC: Energy storage rules | June 19, 2017
This filing represents the Clean Coalition’s comments suggesting that energy storage rules allow greater flexibility and equal footing for all technologies by focusing rules on functions rather than technologies.

CPUC: DSO model for customer and retail energy choice | June 16, 2017
This filing represents the Clean Coalition’s comments suggesting that the California Public Utilities Commission (CPUC) and California Energy Commission consider analyzing the distribution system operator (DSO) model as a means of advancing customer and retail energy choice.

CEC: Opposing natural gas plant construction in Oxnard, California | June 14, 2017
This filing represents the Clean Coalition’s comments opposing the Puente Power Project in Oxnard, CA, highlighting the inadequate analysis of distributed energy resources (DER) in the analysis of the impacts of the project. The Clean Coalition opposes the approval of the Puente Power Project and recommends the energy needs of the area be met with DER. Building natural gas plants is inconsistent with California policy goals to reduce the use of fossil fuels in the energy sector, because such construction locks in the use of fossil fuels for the many decades of the natural life of the project.

CPUC: Grid modernization investment approval process | May 24, 2017
This filing represents the Clean Coalition’s informal opening comments on the California Public Utility Commission’s (CPUC) proposed grid modernization investment approval process. The comments focused on the importance of providing for forward looking investments to respond to policy changes, to provide for value capture for distributed energy rsources, and to support the implementation of distribution system operator functionalities.

CPUC: Scope and scheduling of ICA and LNBA – additional comments | May 10, 2017
This filing represents the Clean Coalition’s comments on the California Public Utilities Commission’s (CPUC) assigned commissioner’s ruling proposing a scope and schedule for the continued longterm refinement of Integration Capacity Analysis (ICA) and Locational Net Benefits Analysis (LNBA) as part of the distribution resources planning proceeding. The Clean Coalition agreed with the proposed scope, schedule, and prioritization, and in addition recommended data access, LNBA use case development, adoption of base transmission valuation, higher prioritization of longterm valuation, and continued development of alternatives or additions to the current avoided cost methodology for clean energy procurement. These comments are in respone to the working group reports developed for this ruling.

CEC: Commercializing Community Microgrids | May 9, 2017
This filing represents the Clean Coalition’s comments in response to the April 25th Joint Energy Agency (California Energy Commission (CEC), California Public Utilities Commission, California Independent System Operator) Workshop for the Development of a Roadmap to Commercialize Microgrids in California. The comments encouraged the CEC to make funds available to stage, design, and plan Community Microgrids in each utility service territory that would pilot the successful German wholesale distributed generation model of distributed energy resources in California. The comments also address the enormous potential for Community Microgrids to replace peaker plants and synchronous condensers at the utility distribution level, to prevent the repowering of peaker plants such as the Elwood Peaker Plant. Finally, the comments describe how the Clean Coalition is addressing various policy and financial barriers, but encourage the CEC to make funding availble to research the barriers and develop appropriate, timely solutions.

CPUC: Rejecting Ellwood Peaker Plant refurbishment | May 5, 2017
This filing represents the Clean Coalition’s ex parte letter to California Public Utilities Commission (CPUC) commissioners in support of the proposed decision rejecting the Ellwood Peaker Plant refurbishment project in Santa Barbara County, California. The Ellwood Peaker Plant fails to be the best solution to suggested energy resiliency standards. Grid resilience is becoming increasingly critical to California as climate change impacts magnify storm and wildfire impacts to the grid. Ellwood fails to meet grid resilience needs, let alone represent the best, most reliable, or cost-effective technology to meet any such need.

CPUC: Scope and scheduling of ICA and LNBA | May 3, 2017
This filing represents the Clean Coalition’s comments on the California Public Utilities Commission’s (CPUC) assigned commissioner’s ruling proposing a scope and schedule for the continued longterm refinement of Integration Capacity Analysis (ICA) and Locational Net Benefits Analysis (LNBA) as part of the distribution resources planning proceeding. The Clean Coalition agreed with the proposed scope, schedule, and prioritization, and in addition recommended data access, LNBA use case development, adoption of base transmission valuation, higher prioritization of longterm valuation, and continued development of alternatives or additions to the current avoided cost methodology for clean energy procurement.

CPUC: Renewable Market Adjusting Tariff at risk of being discontinued | April 27, 2017
This filing represents the Clean Coalition’s letter to California Public Utilities Commission (CPUC) Commissioner Clifford Rechtschaffen to express urgent concern regarding the status of the Renewable Market Adjusting Tariff (ReMAT) program and the impending risk that the streamlined ReMAT procurement program may be discontinued despite widespread utility failure to procure authorized renewable energy capacity. The Clean Coalition requested that the CPUC take immediate action to maintain access to the ReMAT program while considering active Petitions for Modifications and other rule changes to facilitate a more efficient program and ensure fulfillment of the program’s procurement targets, given its importance as a mechanism to support and foster demand for distributed renewable generation within California.

CPUC: Societal costs of energy – reply comments | April 6, 2017
This filing represents the Clean Coalition’s reply comments regarding the adoption of a Social Cost Test for the consistent evaluation of distributed energy resources, including greenhouse gas value and use of a 3% “social discount” rate. These reply comments responded to utility opening comments opposing the use of a social discount rate and advocating for market discount rates to apply to future costs and benefits. The Clean Coalition offered an economic and philosophical rebuttal in our abbreviated comments. Costs associated with energy choices directly impact society at large, and decisions regarding energy options must reflect these costs in order to avoid inappropriate cross subsidies or transfers of cost responsibility between stakeholders.

CPUC: Societal costs of energy | March 23, 2017
This filing represents the Clean Coalition’s opening comments supporting the California Public Utilities Commission’s (CPUC) Staff Proposal regarding the adoption of a Social Cost Test for the consistent evaluation of distributed energy resources, including greenhouse gas value and use of a 3% “social discount” rate. These comments advocated for adoption of the Staff Proposal, extension of application to all resources, and improved assessment when valuing avoided transmission costs. Costs associated with energy choices directly impact society at large, and decisions regarding energy options must reflect these costs in order to avoid inappropriate cross subsidies or transfers of cost responsibility between stakeholders.

CPUC: Preventing fossil-fueled generation in the utility regulatory incentive pilot | February 7, 2017
This filing represents the Clean Coalition’s response — along with the Environmental Defense Fund and Natural Resources Defense Council — to the Sierra Club’s Application for Rehearing of the “Decision Addressing Competitive Solicitation Framework and Utility Regulatory Incentive Pilot.” The response urged the California Public Utilities Commission (CPUC) to act quickly to prevent the unlawful participation of fossil-fueled generation resources in the utility regulatory incentive pilot and any other sourcing conducted under the authority of Public Utilities Code Section 769(a).

CPUC: Supporting fast-track interconnection processes with DER demo projects | February 6, 2017
This filing represents the Clean Coalition’s reply comments on California Public Utilities Commission (CPUC) Administrative Law Judge Peter Allen’s Proposed Decision on Track 2 Demonstration Projects, dated January 10, 2017. The Clean Coalition generally supports the balanced approach of the Proposed Decision and its approval of a number of distributed energy resource (DER) demonstration projects. These reply comments respectfully urge the CPUC to additionally approve the “Click and Claim” automated interconnection process for possible inclusion in the investor-owned utilities’ (IOU) demonstration projects. This inclusion would continue to streamline IOU interconnection processes and achieve additional cost reductions, supporting other fast-track interconnection processes already in place.

CEC: Renewable Energy Transmission Initiative 2.0 | January 10, 2017
This filing represents the Clean Coalition’s comments on the Renewable Energy Transmission Initiative 2.0 Plenary Report Public Review Draft, emphasizing that California’s transmission needs to meet Renewable Portfolio Standards and greenhouse gas targets will require consideration in the growth of distributed generation (DG) resources. In many cases, DG resources will be able to meet additional energy needs without transmission investsment and may be cost-effective alternatives to centralized renewables and the transmission investments needed to support them. In addition, the comments highlighted the Transmission Access Charges market distortion on DG resources and how that may distort the projected need for additional transmission.

CAISO: 2017 Stakeholder Initiative Roadmap | January 9, 2017
This filing represents the Clean Coalition’s comments on the California Independent System Operator’s (CAISO) Draft Final 2017 Stakeholder Initiative Roadmap, noting that the start date for the Review Transmission Access Charges (TAC) Structure stakeholder has been moved to January 2017 in order to begin analysis of the issue. To assist in this effort, the Clean Coalition attached a list of factual disagreements that arose in the predecessor stakeholder initiative so that the new stakeholder initiative may begin with a common understanding of the underlying facts.

2016

CPUC: Expanding DER and alternative utility business models – reply comments | December 5, 2016
This filing represents the Clean Coalition’s reply comments on the California Public Utilities Commission’s (CPUC) Proposed Decision Addressing Competitive Solicitation Framework and Utility Regulatory Incentive Pilot. The Clean Coalition strongly supports the CPUC’s continued efforts both in establishing sourcing mechanisms to animate the market for distributed energy resources and in exploring alternative utility business models. In the comments, the Clean Coalition broadly supported party recommendations for refinements to the proposed utility regulatory incentive pilot and role of the Distribution Planning Advisory Group, proposed use of data sources to indicate price viability ranges, inclusion of Conservation Voltage value, and specifically opposed new proposals for more burdensome approval processes and prohibition of projects below 5 MW.

CPUC: Expanding DER and alternative utility business models | November 30, 2016
This filing represents the Clean Coalition’s opening comments on the California Public Utilities Commission’s (CPUC) Proposed Decision Addressing Competitive Solicitation Framework and Utility Regulatory Incentive Pilot. The Clean Coalition strongly supports the CPUC’s continued efforts both in establishing sourcing mechanisms to animate the market for distributed energy resources (DER) and in exploring alternative utility business models. In the comments, the Clean Coalition recommended several improvements to the competitive solicitation framework and the utility regulatory incentive pilot.

CAISO: 2017 Stakeholder Initiatives Catalog forum and Transmission Access Charges recommendations | November 17, 2016
This filing represents the Clean Coalition’s submitted comments at the California Independent System Operator’s (CAISO) Stakeholder Initiatives Catalog forum to emphasize the need to address the Transmission Access Charges (TAC) market distortion before issues related to CAISO expansion. In addition, the Clean Coalition outlined a solution to both the market distortion and questions related to expansion, including adjusting the TAC billing determinants to the relevant transmission energy downflow for each voltage category of transmission facilities (low voltage and high voltage) and creating a third superhigh voltage category that would be eligible for region-wide cost allocation. Read more on the TAC Campaign here.

CAISO: 2017 initiatives and the Transmission Access Charge wholesale billing determinant | September 29, 2016
This filing represents the Clean Coalition’s initial comments on the California Independent System Operator’s (CAISO) new catalog of initiatives planned for 2017, addressing the Transmission Access Charge (TAC) wholesale billing determinant and CAISO’s subsequent review. The comments aim to ensure stakeholders are aware of the expanded scope and opportunity to participate in 2017. Read more on the TAC Campaign here.

CPUC: Commissioner Florio’s revised regulatory incentive mechanism pilot proposal | September 15, 2017
This filing represents Clean Coalition’s comments on the California Public Utilities Commission (CPUC) Commissioner Florio’s revised regulatory incentive mechanism pilot proposal in the Integrated Distributed Energy Resources proceeding. The comments generally support the revised proposal and the CPUC’s continued work on the matter. The Clean Coalition recommended the CPUC dedicate further attention to the evolving utility business environment, appropriate business models to align incentives with ratepayer interest, and other public policy goals. The revised proposal should be only one piece of the much broader policy framework that is required to promote the widespread utilization of cost-effective distributed energy resources, and the Clean Coalition recommended the creation of a roadmap and working groups to realize that objective.

CPUC: Response to concept paper on Integrated Resource Planning | August 31, 2016
This filing represents the Clean Coalition’s response to the California Public Utilities Commissions’s (CPUC) concept paper on the Integrated Resource Planning (IRP) process. The Clean Coalition recommended that the IRP procurement directives incorporate and support established procurement directives from other proceedings into the development of any preferred resources portfolio. Additionally, the comments noted the need for continued coordination with other proceedings, including Least-Cost Best-Fit reforms, the plans to retire the Diablo Canyon Nuclear Power Plant, the Distributed Resources Plan, and Integrated Distributed Resources proceedings. The Clean Coalition also noted an opportunity to pilot the Distribution System Operator concept in this proceeding.

CPUC: Interconnection status eligibility requirements for BioMAT projects – reply comments | August 31, 2016
This filing represents the Clean Coalition’s reply comments to a request from the California Public Utilities Commission (CPUC) on the impact and implementation of proposed legislation related to the BioFIT feed-in tariff procurement program for biofuel based generation. The Clean Coalition offers recommendations regarding interconnection status eligibility requirements that ensure projects with contracts are able to deliver on schedule without initiating incompatible interconnection commitments. These recommendations are broadly applicable to other procurement programs and reflect the Clean Coalition’s recommendations for revisions to California’s Renewable Energy Market Adjusting Tariff (ReMAT).

CAISO: Distributed energy resources as transmission alternatives | August 25, 2016
This filing represents the Clean Coalition’s filing in response to the California Independent System Operator’s (CAISO) TAC Options Stakeholder Working Group Meeting. The Clean Coalition submitted comments regarding the proposed default cost allocation process for new transmission projects over 200 kV. The Clean Coalition emphasized that CAISO should consider distributed energy resources as transmission alternatives when calculating the possible avoided cost savings of any proposed transmission project. We encourage the CAISO to engage with the California Public Utilities Commission and California Energy Council in order to fully investigate non-transmission alternatives as alternatives to proposed transmission projects. If this recommendation is adopted, California ratepayers will benefit from cost-effective decisions regarding transmission investments.

CPUC: Interconnection status eligibility requirements for BioMAT projects | August 24, 2016
This filing represents the Clean Coalition’s response to a request from the California Public Utilities Commission (CPUC) for comments on the impact and implementation of proposed legislation related to the BioFIT feed-in tariff procurement program for biofuel based generation. The Clean Coalition offers recommendations regarding interconnection status eligibility requirements that ensure projects with contracts are able to deliver on schedule without initiating incompatible interconnection commitments. These recommendations are broadly applicable to other procurement programs and reflect the Clean Coalition’s recommendations for revisions to California’s Renewable Energy Market Adjusting Tariff (ReMAT).

CPUC: Defining the role of DER and setting long-term goals | August 22, 2016
This filing represents the Clean Coalition’s comments in response to the California Public Utilities Commission’s (CPUC) Assigned Commissioner’s Ruling to consolidate and narrow remaining topics primarily addressing policy issues. The Clean Coalition supports the coordination of distribution resources plans, integrated distributed energy resources, and other proceedings with a clear CPUC vision of long-term goals with respect to the future role of distributed energy resources (DER) operations and markets, including future utility business models.

CPUC: Distribution Resources Plan demonstration projects | July 29, 2016
This filing represents the Clean Coalition’s reply comments on the Distribution Resources Plan Track 2 Demonstration Projects. These projects validate the Track 1 Locational Net Benefits Assessment and hosting capacity assessments, the ability of utilities to utilize Distributed Energy Resources (DER) in grid operations, integrate high penetration levels of DER, and utilize these resources to avoid more costly conventional distribution infrastructure investment. In these reply comments we further support parties interested in accelerating deployment and ensuring an appropriate variety of scenarios and approaches are addressed, including sourcing mechanisms.

CPUC: Challenging PG&E’s motion to delay Renewable Auction Mechanism auctions | July 29, 2016
This filing represents the Clean Coalition’s response to Pacific Gas & Electric’s (PG&E) motion to suspend Renewable Aution Mechanism (RAM) auctions. The Clean Coalition opposed PG&E’s motion as the delay would lead to substantial losses for developers and higher costs to ratepayers, in part due to the expiration of tax credits. We also insisted that PG&E’s justifications were insufficient to delay the steady and consistent procurement of Renewable Portfolio Standard resources. We challenged PG&E’s suggestions that the delay may result in further cost reductions for renewables.

CPUC: Future development of demand response programs | July 1, 2016
This filing represents the Clean Coalition’s response to ‘Administrative Law Judge’s (ALJ) Questions on Future Development of Demand Response (DR) Programs,’ which focuses on the goals and metrics for development. The Clean Coalition emphasizes the integral relationship of DR with other distributed energy resources and the related proceedings, including both transmission and distribution planning and operation. We also address issues with market design and participation, and introduce the role of a Distribution System Operator as an appropriate market and dispatch intermediary to ensure optimal utilization of resources and highest value dispatch and application with consideration of locational factors.

CAISO: Transmission Access Charge wholesale billing determinant | June 30, 2016
This filing represents the Clean Coalition’s comments on the California Independent System Operator’s (CAISO) issue paper on the Transmission Access Charge (TAC) wholesale billing determinant. The Clean Coalition defended its proposal to change the TAC wholesale billing determinant from the end-use metered load (or, customer energy downflow) to the transmission energy downflow. If enacted, this change would result in lowering costs on distributed generation and, over time, defer or avoid transmission investment and lower transmission revenue requirements. Read more on the TAC Campaign here.

CPUC: Resource adequacy and demand-side resources | June 29, 2016
Issues and Workshop Report to support distributed energy resources in refinements to the RA program. The comments recommended unbundling Net Qualifying Capacity and Effective Flexible Capacity to ensure that demand-side resources are allowed to participate in the RA market. Additionally, the comments recommended that demand-side resources be incorporated into the 2020 and 2022 projections and that any new proposals regarding Maximum Cumulative Contribution buckets allow two-hour resources to participate and allow resources to be aggregated.

CPUC: Reforming the Power Charge Indifference Adjustment – reply comments | June 27, 2016
This fiing represents the Clean Coalition’s reply comments on the California Public Utilities Commission’s (CPUC) draft Power Charge Indifference Adjustment (PCIA) Inputs and Methodologies Workshop Report. These reply comments were filed jointly with Marin Clean Energy, Sonoma Clean Power, the City of Lancaster, the City and County of San Francisco, the County of Los Angeles, Lean Energy US, and Communities for a Better Environment. The PCIA is a charge or credit that is intended to ensure that customers who purchase electricity from non-utility suppliers pay their share of cost for generation acquired. The reply comments draw attention to many issues with the PCIA that deserve greater attention. The Clean Coalition and the joint parties requested that the CPUC provide a venue for consideration of PCIA reform.

CPUC: Reforming the Power Charge Indifference Adjustment | June 20, 2016
This fiing represents the Clean Coalition’s comments on the California Public Utilities Commission’s (CPUC) draft Power Charge Indifference Adjustment (PCIA) Inputs and Methodologies Workshop Report. These comments were filed jointly with Marin Clean Energy, Sonoma Clean Power, the City of Lancaster, the City and County of San Francisco, the County of Los Angeles, Lean Energy US, and Communities for a Better Environment. The PCIA is a charge or credit that is intended to ensure that customers who purchase electricity from non-utility suppliers pay their share of cost for generation acquired. The comments draw attention to many issues with the PCIA that deserve greater attention. The Clean Coalition and the joint parties requested that the CPUC provide a venue for consideration of PCIA reform.

CAISO: Transmission Access Charges in a potential CAISO expansion | June 10, 2016
This filing represents the Clean Coalition’s comments in the Transmission Access Charges (TAC) options stakeholder initiative, which is reviewing how to allocate transmission costs in an expanded California Independent System Operator (CAISO) balancing authority area. The comments highlighted how the Clean Coalition’s proposed TAC fix might apply in an expanded CAISO jurisdiction. We advocated for a simplified cost allocation approach based on sharing the cost of each applicable category of transmission voltage (superhigh, high, and low) in proportion to usage. This would align transmission usage with transmission charges and incentivize cost-effective investment in local distributed energy resources.

CAISO: Transmission Access Charges stakeholder initiative | June 9, 2016
This filing represents the Clean Coalition’s brief comments in reaction to the California Independent System Operator’s (CAISO) launch of a new stakeholder initiative to address the impact of Transmission Access Charges (TAC) on distributed energy resources. The Clean Coalition supported the timely review and resolution of the TAC issue and distinguished the issue from CAISO’s concern of disincentivizing energy use during peak load conditions.

CPUC: Resource adequacy and demand response | June 9, 2016
This filing represents that Clean Coalition’s comments in response to the California Public Utilities Commission (CPUC) Track 1 Proposed Decision on resource adequacy in demand response programs. The Clean Coalition advocated that the CPUC decline the proposal to adopt a 20-minute response time for demand response programs, and urged them to adopt the proposal to include partially integrated demand response programs that aggregate smaller market participants. These adjustments would allow utilities the opportunity to use a variety of demand response programs to meet their resource adequacy requirements.

NY PSC: Utility codes of conduct | June 6, 2016
This filing represents the Clean Coalition’s comments on the New York Public Services Commission (NY PSC) Staff’s Proposed Guiding Principles for Revised Utility Codes of Conduct. We supported the NY PSC’s effort to prohibit potential conflicts of interest between utilities and distributed energy resource suppliers and recommended additional improvements to the principles. For example, the Clean Coalition advocated for internal communication walls between utility departments when a utility manages both competitive solicitations and distribution services. The Clean Coalition also proposed that the NY PSC provide oversight for resolving formal complaints against utilities that improperly manage any potential conflicts of interest.

CPUC: Renewable integration cost adders | June 3, 2016
This filing represents the Clean Coalition’s comments on the limitations of methodologies seeking to identify values for the renewable integration cost adders (RICA) required by Assembly Bill 2363 in California. We urged the California Public Utilities Commission (CPUC) to adopt a more comprehensive, integrated resource planning process to take full account of integration costs associated with all resources, not just renewables. We further advocated that the CPUC consider Renewable Portfolio Standard-eligible resources as part of the baseline before identifying and assessing marginal integration costs.

CPUC: IDER cost-effectiveness framework – Joint Party comments | May 31, 2016
This filing represents the Joint Parties agreement with the opening comments supporting the proposed decision’s update of the Integrated Distributed Energy Resources (IDER) cost-effectiveness framework by eliminating the role of the resource balance year (RBY) in measuring the capacity benefits of distributed energy resources. The Clean Coalition along with the Joint Parties urges the California Public Utilities Commission (CPUC) to reject The Utility Reform Network’s proposal to eliminate the RBY only on an interim basis. The investor-owned utilities and the Office of Ratepayer Advocates raise several flawed arguments against this update, which the CPUC should reject. The “Joint Parties” include the Sierra Club, Natural Resources Defense Council, Clean Coalition, Karey Christ-Janer, Robert Bosch LLC, Vote Solar, Comverge, Inc., Enernoc, Inc., and Cpower.

CPUC: Interconnection cost certainty and a cost envelope option – reply comments | May 31, 2016
This filing represents the Clean Coalition’s reply comments in support for the California Public Utilities Commission’s (CPUC) Alternate Proposed Decision adopting our joint motions and recommendations to provide cost certainty for distributed energy interconnection applicants through a guaranteed cost envelope option. The Clean Coalition supports minor utility modifications, but opposes a proposal to shorten the initial program to three years.

CPUC: Interconnection cost certainty and a cost envelope option | May 26, 2016
This filing represents the Clean Coalition’s opening comments in support for the California Public Utilities Commission’s (CPUC) Alternate Proposed Decision adopting our joint motions and recommendations to provide cost certainty for distributed energy interconnection applicants through a guaranteed cost envelope option.

CEC/CPUC/CAISO: A roadmap to commercialize microgrids in California | May 25, 2016
This filing represents the Clean Coalition’s comments following a Joint Energy Agency Workshop hosted by the California Energy Commission (CEC), the California Public Utilities Commission (CPUC), and the California Independent System Operator (CAISO). The workshop kicked off the ‘Development of a Roadmap to Commercialize Microgrids in California.’ It introduced a proposed work scope and described the process for developing a coordinated agency roadmap to commercialize microgrids in the state. The Clean Coalition’s comments describe our Community Microgrid concept and pilot projects. Community Microgrids are a new approach for designing and operating the electric grid in a manner that leverages existing grid assets to cost-effectively increase reliability and support integration of clean distributed energy resources. The Clean Coalition urges the joint agencies to incorporate this concept into the roadmap.

CPUC: Supporting interconnection modifications for BioMAT projects | May 25, 2016
This filing represents the Clean Coalition’s support for a proposal to modify interconnection based on eligibility requirements for BioMAT, which are projects utilizing byproducts of sustainable forest management for fuel. In addition, we recommend that the California Public Utilities Commission (CPUC) review and revise the project viability requirements and eligibility to enter the procurement queue in light of their impact on successful price adjustment and procurement for all BioMAT and other Renewable Market Adjusting Tariff procurement programs.

CPUC: DER and changes to net revenue – reply comments | May 23, 2016
This filing represents the Clean Coalition’s reply comments on a Distributed Energy Resources (DER) incentive proposal to allow utilities to receive the same net revenue relative to cost of procuring capacity and services from DER not owned by the utility as they would from conventional utility investment in grid infrastructure when these DER can be substituted as lower net cost to ratepayers. The Clean Coalition strongly supports this effort, seeks to address the regulatory business model more broadly, and offers critical guidance from recent research and a seminal ruling on this topic in New York.

CPUC: Improving data access in Distribution Resources Plans | May 13, 2016
This filing represents the Clean Coalition’s response to a ruling instructing parties to answer a data request in relation to Distribution Resource Plan Locational Net Benefits Assessment (LNBA) and Interconnection Capacity Analysis (ICA). The comments support making publicly available data more readily accessible and usable, including through interactive grid maps and searchable databases, while creating a stakeholder driven process to increase the quantity and quality of data that can be made publicly available, both from utilities to the public and from third party distributed energy resources providers to utilities.

CPUC: DER and changes to net revenue | May 9, 2016
This filing represents the Clean Coalition’s opening comments on a Distributed Energy Resources (DER) incentive proposal to allow utilities to receive the same net revenue relative to cost of procuring capacity and services from DER not owned by the utility as they would from conventional utility investment in grid infrastructure when these DER can be substituted as lower net cost to ratepayers. The Clean Coalition calls for longer term changes in the regulated utility business model to align shareholder interest with ratepayer and public policy goals, and a roadmap for investigation, development, and implementation of these changes. The Clean Coalition supports the proposal as an interim measure with the aim of mitigating existing utility incentive to prefer capital investment over the use of DER.

CPUC: More refinement recommendations for the Green Tariff Shared Renewables program | May 9, 2016
This filing represents the Clean Coalition’s reply comments filed jointly with the Sustainable Economies Law Center and the California Environmental Justice Alliance on the Proposed Decision Addressing Participation of Enhanced Community Renewables Projects in the Renewable Auction Mechanism and Other Refinements to the Green Tariff Shared Renewables Program. The comments suggest changes to the proposed decision that would more closely align the program with the intent of California Senate Bill 43 (SB 43), which mandates expanded shared renewables.

CPUC: Recommendations for the Green Tariff Shared Renewables program | May 2, 2016
This filing represents the Clean Coalition’s opening comments on recommended changes to the Green Tariff Shared Renewables program in California. First, the California Public Utility Commission (CPUC) should allow sub-500 kilowatt resources to participate in the program, pending the Federal Energy Regulatory Commission approving the California Independent System Operator’s (CAISO) tariff filing that seeks to facilitate participation of aggregations of distribution-connected resources in CAISO’s energy and ancillary services markets. Second, the CPUC should require the utilities to revisit the program through advice letters in order to monetize additional value streams as they develop.

CAISO: Transmission Access Charges (TAC) comments in ESDER Phase 2 | April 18, 2016
This filing represents the Clean Coalition’s opening comments in the California Independent System Operator (CAISO) Energy Storage and Distributed Energy Resources (ESDER) Phase 2 Stakeholder Initiative on April 18, 2016. The CAISO requested stakeholder comments on a number of issues, including the impact of transmission access charges (TAC) on distributed energy resources. The Clean Coalition’s comments highlight that the current TAC assessment process in PTO utility service territories artificially decrease the value of distributed energy resources and propose that the TAC assessment point be moved from the customer gross load to the transmission energy downflow for all California service territories. Detailed information on the Clean Coalition’s TAC campaign can be found here.

NY PSC: Compensating DER for their environmental and locational benefits | April 18, 2016
This filing represents the Clean Coalition’s jointly filed comments along with the Clean Energy Organizations Collaborative in proposing principles and methodologies to guide both the selection of an interim successor to net energy metering (NEM), as well as the long-term task of developing rates to compensate distributed energy resources (DER) for their locational and environmental benefits.

CPUC: NEM + storage bill credit estimation reply comments | March 29, 2016
This filing represents the Clean Coalition’s reply comments on the California Public Utility Commission’s (CPUC) Proposed Decision (PD) on adopting a net energy metering (NEM) bill credit estimation methodology for generating facilities paired with small storage devices. The Clean Coalition strongly supports the CPUC’s PD to adopt an estimation methodology for determining NEM credits for storage devices with a capacity of 10 kW or less that have been installed as an addition or enhancement to NEM-eligible generation facilities. The CPUC’s adoption of the second estimation methodology proposed in the November 4, 2014 Assigned Commissioners Ruling that caps NEM credits for exports based on modeled monthly generation is preferable because it provides the greatest system benefits.

CPUC: NEM + storage bill credit estimation | March 24, 2016
This filing represents the Clean Coalition’s comments on the California Public Utility Commission’s (CPUC) Proposed Decision (PD) on adopting a net energy metering (NEM) bill credit estimation methodology for generating facilities paired with small storage devices. The Clean Coalition strongly supports the PD for storage devices with a capacity of 10 kW or less that have been installed as an addition or enhancement to NEM-eligible generation facilities.

CAISO: Transmission Access Charges (TAC) straw proposal | March 23, 2016
This filing represents the Clean Coalition’s comments on the California Independent System Operator’s (CAISO) straw proposal to adjust the Transmission Access Charges (TAC) system to account for their planned regional expansion. The Clean Coalition used this opportunity to highlight the existing market distortion on the cost of distributed energy resources (DER) and explain our proposal to resolve the issue by assessing TAC on Transmission Energy Downflow rather than gross load.

CPUC: Reiterating objection to the Fixed Price Option | March 14, 2016
This filing represents the Clean Coalition’s reply comments on the Proposed Decision following the California Public Utilities Commission’s (CPUC) proceeding on interconnection rules and regulations. The Clean Coalition repeated its objection to the Fixed Price Option and cited widespread support for its position.

CPUC: Objection to the Fixed Price Option | March 7, 2016
This filing represents the Clean Coalition’s comments on the Proposed Decision following the California Public Utilities Commission’s (CPUC) proceeding on interconnection rules and regulations. The Clean Coalition reiterated its objection to the Fixed Price Option and asked the CPUC to include a discussion of a cost envelope approach under cost certainty measures.

CPUC: Integration Capacity Analysis and locational net benefits | March 3, 2016
This filing represents the Clean Coalition’s comments following the California Public Utilities Commission’s (CPUC) Integration Capacity Analysis (ICA) workshop. The comments highlighted the potential of ICA maps to be a useful tool for providing key information on grid capacity to potential developers, particularly developers of distributed energy resources. Additionally, the comments discussed various methodologies for the locational net benefits assessment (LNBA).

CPUC: PG&E petitioning to cancel renewable procurement | February 22, 2016
This filing represents the Clean Coalition’s response to Pacific Gas & Electric’s (PG&E) petition to modify the Renewable Auction Mechanism (RAM) schedule. PG&E seeks to cancel procurement of any additional renewable energy resources in 2016-2017. The Clean Coalition opposes this cancelation of the scheduled procurement as unwarranted and harmful to the development and maintenance of the utility scale distributed renewable energy market and longterm ratepayer impacts.

CPUC: Energy storage proceeding reply comments | February 19, 2016
This filing represents the Clean Coalition’s reply comments on Track 2 issues in the California Public Utility Commission’s (CPUC) energy storage proceeding. The comments centered on maintaining current energy storage procurement targets and addressing cost-recovery, interconnection, and prioritization issues in multiple-use storage applications.

CPUC: Energy storage and the Distributed Service Operator model | February 5, 2016
This filing represents the Clean Coalition’s opening comments on Track 2 issues in the California Public Utility Commission’s (CPUC) energy storage proceeding. The comments focus on multiple-use applications within the energy storage program, in addition to the benefits of transitioning to a Distributed Service Operator model. The Clean Coalition’s position is that utilities should not establish contractual limits on an asset’s use by other parties beyond the obligation to fulfill the services for which the utility has contracted.

CPUC: Resource Adequacy to avoid fossil fuel-based assets | February 5, 2016
This filing represents the Clean Coalition’s comments on Track 2 Question 1 of the California Public Utility Commission’s (CPUC) Resource Adequacy proceedings. The Clean Coalition seeks to encourage a Resource Adequacy program that makes full use of available resources, including distributed resources, in order to avoid procuring potentially redundant capacity or unnecessary fossil fuel-based assets, and to most cost effectively support the development of renewable energy resources.

CPUC: DRP Locational Net Benefits | January 26, 2016
The Clean Coalition filed comments on the Locational Net Benefits Analysis (LNBA) proposals submitted by multiple parties to the California Public Utility Commission’s (CPUC) Distributed Resources Plan (DRP) proceeding. The comments ask to consider Transmission Capacity Value, clearly define the degree to which it is location specific, and ensure that this significant avoided cost component is appropriately allocated for valuation when determining the scope and division of location specific and non-location specific values between the DRP LBNA methods and the CPUC’s Integrated Distributed Energy Resources proceeding.

CPUC: Net Energy Metering successor reply comments | January 15, 2016
This filing represents the Clean Coalition’s response to comments from other parties on the successor to the Net Energy Metering (NEM) tariff in California. The reply comments recommend the following: 1) rejecting the joint utility proposal; 2) reaffirming that systems over 1 MW that pay for interconnection costs and upgrades under Rule 21 will not have a significant impact on the distribution grid; 3) directing utilities to allow utilities to execute interconnection agreements with multiple parties; and 4) ensuring that customer-sited renewable distributed generation continues to grow sustainably.

CPUC: Net Energy Metering successor comments | January 7, 2016
This filing represents the Clean Coalition’s comments on the Proposed Decision Adopting Successor to Net Energy Metering (NEM) Tariff, dated December 15, 2015. In the comments, the Clean Coalition supports the California Public Utilities Commission’s decision to delay further revisions of the NEM successor tariff to 2019—when more comprehensive reform of residential rates is complete and pertinent information from the Distribution Resources Plans (DRP) and Integrated Distributed Energy Resources (IDER) proceedings is available. The Clean Coalition also offered several recommendations to improve aspects of the Proposed Decision, addressing mandatory time-of-use rates, systems larger than 1 MW, and how the NEM proceeding should interact with the DRP and IDER proceedings.

NY PSC: Reply comments to the Distributed System Implementation Plan Guidance Proposal | January 6, 2016
The Clean Coalition joined the Clean Energy Organizations Collaborative to provide reply comments on the NY Department of Public Service’s Distributed System Implementation Plan (DSIP) Guidance Proposal. The reply comments focus on six key issues raised in other parties’ comments: 1) staff should clarify the DSIP process and timeline; 2) request for proposals should be used to procure Distributed Energy Resources; 3) Advanced Metering Infrastructure should be evaluated consistently on the basis of cost-effectiveness; 4) stakeholder input should be robust and independent; and 5) data access should not be determined solely by the utilities.

2015

CPUC: Proper implementation of ReMAT | December 16, 2015
This filing represents the Clean Coalition’s response to the Petition of Solar Electric Solutions to improve Renewable Market Adjusting Tariff (ReMAT) interconnection processes. The response urges the California Public Utilities Commission (CPUC) to ensure that ReMAT is properly implemented and to prevent a significant amount of program capacity from expiring.

CPUC: Green Tariff Shared Renewables Phase IV Track B | December 9, 2015
This filing represents the Clean Coalition’s comments on the California Public Utilities Commission’s Phase IV Track B issues in the Green Tariff Shared Renewables proceeding. These topics were covered: (1) the need to extend program eligibility to sub-500 kW projects, (2) the benefits of procuring resources other than solar, and (3) support for utilizing a modified ReMAT procurement mechanism.

NY PSC: Distributed System Implementation Plan Guidance Proposal | December 7, 2015
The Clean Coalition joined the Clean Energy Organizations Collaborative to provide comments on the NY Department of Public Service’s Distributed System Implementation Plan (DSIP) Guidance Proposal. The Clean Coalition asked that the NY PSC provide more clarity in two areas. First, that the staff should provide more guidance on how utilities should facilitate the role of market participants in developing DER. Second, that the staff should provide more guidance on what utilities should do for those customers, sectors, services, and technologies that market participants are not able or willing to serve. We also recommended that the staff require each utility provide a complete description of the full potential for cost-effective DER, regardless of whether the resource is implemented by the utility or by market participants.

CPUC: Utilizing the Renewables Auction Mechanism (RAM) | November 20, 2015
This filing represents the Clean Coalition’s comments, per the California Public Utilities Commission’s request, on utilizing the Renewables Auction Mechanism (RAM) as an Enhanced Community Renewables procurement tool in the Green Tariff Shared Renewables (GTSR) proceeding.

CPUC: The DRP Roadmap in California | November 20, 2015
This filing represents the Clean Coalition’s comments on the California Public Utilities Commission’s Distribution Resource Plan (DRP) Roadmap Straw Proposal. The comments emphasize the need to address interconnection and the role of the new Interconnection Capacity Analysis of each utility’s distribution grid.

CAISO: Unfair Transmission Access Charges (TAC) on local renewables | November 20, 2015
This filing represents the Clean Coalition’s comments on Transmission Access Charges (TAC) in response to a CAISO issue paper. TAC are assessed on utlilities regardless of what portion of their load is served by non-transmission resources such as local distributed generation. As a result, local generation is not valued properly and the development of local renewable resources is depressed. Demand for additional transmission is then artificially increased, which creates higher costs for ratepayers. Detailed information on the Clean Coalition’s TAC campaign can be found here.

CPUC: PG&E joint motion to streamline Rule 21 for storage devices | November 18, 2015
This filing represents a joint motion filed by Pacific Gas & Electric, with the Clean Coalition’s support, supporting revisions to streamline Rule 21 for behind-the-meter, non-exporting storage devices, including the treatment of associated loads in interconnection review and cost responsibility.

CPUC: Load modifying demand response resources | November 10, 2015
This filing represents the Clean Coalition’s reply comments on the California Public Utilities Commission’s (CPUC) proposed decision addressing the valuation of load modifying demand response and demand response cost-effectiveness protocols. The Clean Coalition urged the CPUC to give particular attention to the matter of capacity value for load modifying demand response resources.

CPUC: Southern California Edison supports Clean Coalition cost guide | November 9, 2015
This filing represents Southern California Edison’s joint motion filing in support of a Clean Coalition initiative to generate a cost guide to provide transparency, predictability, and consistency in interconnection pricing.

CPUC: Green Tariff Shared Renewables Phase IV | November 9, 2015
This filing represents the Clean Coalition’s comments on Phase IV of the California Public Utilities Commission’s Green Tariff Shared Renewables (GTSR) proceeding. The Clean Coalition submitted comments on: the need to extend program eligibility to sub-500 kW projects, the benefits of utilizing a modified ReMAT procurement mechanism, and more accurately reflecting distribution costs and benefits of GTSR projects by exempting eligible participants from Transmission Access Charges.

NY PSC: New York’s Reforming the Energy Vision Track 2 | October 26, 2015
This filing represents the Clean Coalition’s comments, filed jointly with the Clean Energy Organizations Collaborative, on Track 2 of New York’s Reforming the Energy Vision (REV) proceeding. The comments agree with proposals to revise utility revenue models, establish earning incentive mechanisms and scorecard metrics, and offer pre-approval for certain DER-related investments.

CT DEEP: Connecticut demonstration projects to integrate DER | October 13, 2015
This filing represents the Clean Coalition’s comments urging the Connecticut Department of Energy and Environmental Protection (DEEP) to primarily focus on investment opportunities that leverage existing grid assets to cost effectively provide the most value to ratepayers. These comments were submitted in response to DEEP’s Notice of Proceedings and Opportunity for Public Comment concerning demonstration projects for grid-side system enhancements to integrate DER. The comments highlighted how Community Microgrids can ensure that investments in demonstration projects are made efficiently.

CEC: Transmission Access Charges (TAC) | September 24, 2015
This filing represents the Clean Coalition’s comments raising awareness of Transmission Access Charges (TAC) allocation issues. The comments address how the application of TAC affect the ability of non-transmission dependent distributed generation to avoid investment in transmission infrastructure. Correction of the issue would support more accurate least cost and best fit procurement of renewable resources and associated transmission facilities.

NY PSC: Benefit-Cost Analysis in New York REV | September 10, 2015
The Clean Coalition, as a member of the Clean Energy Organizations Collaborative (CEOC), submitted reply comments on the “Staff White Paper on Benefit-Cost Analysis in the Reforming the Energy Vision Proceeding.” The White Paper took significant steps toward developing an effective Benefit-Cost Analysis (BCA) for use in the Reforming the Energy Vision (REV) effort. The comments urged the strengthening and improvement of the BCA framework. Multiple intervenors argued that environmental externalities should not be included in the BCA, and the Clean Coalition’s reply comments rebutted several of their arguments.

CPUC: Net Energy Metering successor tariff | September 1, 2015
This filing represents the Clean Coalition’s general positions regarding the successor to the California Public Utilities Commission’s (CPUC) net energy meeting (NEM) tariff. Through Rulemaking 14-07-002, the CPUC will develop a successor to the existing NEM tariff for eligible customer-generators. Party proposals for the successor tariff were submitted in early June 2015, followed by the Clean Coalition’s comments.

CPUC: DRP proposals from California utilities – overview | August 31, 2015
This filing represents the Clean Coalition’s comments, filed jointly, on the Distribution Resources Plans (DRP) filed by the three major utilities in California. These comments identify issues reflecting the shared perspective of the majority of parties at a high level. The Clean Coalition and other parties also filed individual comments providing detail and addressing additional issues.

CPUC: Green Tariff Shared Renewables | August 28, 2015
This filing represents the Clean Coalition’s reply to opening Track A comments on the California Public Utilities Commission’s Green Tariff Shared Renewables proceeding, which is designed to allow PG&E, SCE, and SDG&E customers to receive 50-100% of their electricity demand from solar generation. The comments specifically focus on making the program more affordable for participants and the appropriate procurement tool for the enhanced community renewables component of the program.

NY PSC: Benefit-Cost Analysis in REV | August 21, 2015
This filing represents the Clean Coalition’s input on a Benefit-Cost Analysis White Paper issued by the New York Department of Public Service as part of a request for utility proposals within the Reforming the Energy Vision proceeding. The Clean Coalition offered insights including applying an appropriate discount rate, valuing functions of distributed energy resources, importing lessons from California’s Distribution Resources Plans proceeding, considering interconnection practices, and valuing non-energy benefits.

CAISO: Energy storage integration in the ISO market | August 18, 2015
This filing represents the Clean Coalition’s comments on the California Independent System Operator’s Issue Paper and Straw Proposal under the energy storage and distributed energy resources initiative. The comments focused on the best methods to integrate different types of energy storage resources into the ISO market, focusing specifically on the benefits of utilizing a distributed service operator model to manage the resources.

CARB: Achieving Greenhouse Gas Reduction Goals | August 7, 2015
This filing represent’s the Clean Coalition’s comments, along with the California Air Resources Board, on the Joint Agency Symposium on achieving the Greenhouse Gas (GHG) Reduction Goals. Cost effective reduction of GHG emissions requires accurate assessment of the cost of alternatives and selection of the lowest total net cost option. Correction of this cost allocation would support accurate least cost and best fit procurement of resources required to reduce GHG emissions.

CPUC: Energy storage procurement best practices | August 3, 2015
This filing represents the Clean Coalition’s reply comments on the California Public Utilities Commission’s energy storage program, offering input on procurement best practices in the energy-storage specific request for offer process and refinements to the Consistent Evaluation Protocol.

CPUC: Load Modifying Demand Response | July 31, 2015
This filing represents the Clean Coalition’s initial comments addressing specific triggers for dispatch of demand response resources and qualification portfolios for capacity credit following a ruling on the California Public Utilities Commission’s LMDR (Load Modifying Demand Response) Valuation Working Group Report.

CPUC: Load Modifying Demand Response – “hard triggers” | July 30, 2015
This filing represents the Clean Coalition’s participation in a joint motion to enter data into the record regarding “hard triggers” for the California Public Utilities Commission’s Load Modification Demand Response programs.

CPUC: Energy storage best practices | July 8, 2015
This filing represents the Clean Coalition’s comments on the California Public Utilities Commission’s energy storage program, offering input on procurement best practices in the energy-storage specific request for offer process, refinements to the Consistent Evaluation Protocol, and coordination across other Commission proceedings.

CPUC: Improving cost certainty for interconnection | June 8, 2015
This filing addresses the Clean Coalition’s initiative to improve cost certainty associated with interconnection agreements, and to establish standards for the streamlined interconnection of non-exporting energy storage devices.

CPUC: Demand-Side resource programs – workshop ruling | May 29, 2015
This filing represents the Clean Coalition’s replies to a number of parties’ responses to a series of questions resulting from the California Public Utilities Commission’s workshop soliciting feedback on foundational issues within the demand-side resource program proceeding. Through the Rulemaking, the California Public Utilities Commission will develop and adopt a regulatory framework to provide policy consistency for the direction and review of demand-side resource programs.

CPUC: SCE & Demand Response | May 28, 2015
This filing represents the Clean Coalition’s reply to SCE’s response to the Clean Coalition’s April 13, 2015, intervenor compensation claim in Rulemaking 13-09-011. Southern California Edison (“SCE”) requested that the California Public Utilities Commission consider the aggregate amount of all parties’ intervenor compensation claims in the demand response proceeding. The Clean Coalition’s reply argued that SCE’s response is neither supported by statute nor past Commission decisions, and the response provides no basis for how the Commission has or should review intervenor compensation claims in the aggregate. Further, though SCE frames the request as a response to the Clean Coalition’s claim, SCE fails to present specific arguments against the Clean Coalition’s claim—or any of the other referenced parties’ claims. Therefore, the Clean Coalition’s reply concluded that the Commission should deny SCE’s request to aggregate the parties’ intervenor compensation claims.

CPUC: Joint Utility Motions | May 22, 2015
This filing represents the Clean Coalition’s opening comments in the ongoing reform of Rule 21 storage and interconnection processes and the initiative to improve cost certainty associated with interconnection agreements. The Clean Coalition also submitted an alternate proposal in establishing standards for the streamlined interconnection of non-exporting energy storage devices.

CPUC: Demand-side resource programs | May 15, 2015
This filing represents the Clean Coalition’s comments on the California Public Utilities Commission’s (CPUC) development and adoption of a regulatory framework to provide policy consistency for the direction and review of demand-side resource programs. The CPUC hosted a workshop to solicit feedback and the Clean Coalition responded with a series of questions.

NY PSC: Microgrids | May 1, 2015
This filing represents the Clean Coalition’s comments from the New York Public Service Commission’s (“PSC”) solicitation for comments on various configurations of microgrids, as well as a number of legal and policy issues. The Clean Coalition submitted comments that define and highlight one potential community microgrid configuration that should be presumptively permissible. This type of community microgrid will be important in the early stages of REV, as it is both cost-effective and relies on existing organizational and physical infrastructure to achieve REV objectives. The Clean Coalition’s vision is a sort of “no regrets” community microgrid option that fits within REV’s near-term “no regrets” actions.

CPUC: NEM 2.0 | April 28, 2015
This filing represents the Clean Coalition’s submitted comments suggesting minor adjustments to CPUC Energy Division’s demonstrative use of the draft version of the Public Tool, which will model different options for the NEM successor contract or tariff. Administrative Law Judge Simon issued a ruling to allow parties a final opportunity to comment on the development of the Public Tool.

CPUC: Renewable Portfolio Standard (RPS) | April 15, 2015
This filing represents the Clean Coalition’s prehearing comments on the Renewable Portfolio Standard (“RPS”) proceeding. Through Rulemaking 15-02-020, the California Public Utilities Commission (“Commission”) will address implementation, administration, and development of the state’s RPS. The Clean Coalition filed this prehearing conference statement to identify five issues that should have the highest priority in the proceeding. The five issue-areas identified are: (1) RPS Target; (2) DER Contribution to RPS Targets and Cost Effectiveness; (3) Procurement Mechanisms; (4) LCBF and Locational Value; and (5) Transmission Costs.

CPUC: NEM 2.0 | March 30, 2015
This filing represents the Clean Coalition’s reply comments on the ALJ’s ruling on policy issues associated with the development of NEM 2.0. Through Rulemaking 14-07-002, the California Public Utilities Commission will develop a successor to the existing net energy metering (“NEM”) tariff for eligible customer-generators. On February 23, 2015, Administrative Law Judge Simon issued a ruling seeking comment on policy issues of the successor standard contract or tariff—encompassing both the statutory requirements set out in Pub. Util. Code 2827.1(b) and additional elements that are part of the overall administration of the program. In these reply comments, the Clean Coalition responds to a number of proposals put forth by other organizations, including issues concerning interconnection, disadvantaged communities, and sustainable growth of renewable distributed generation.

CPUC: Renewable Portfolio Standard | March 26, 2015
The CPUC opened a new rulemaking regarding the RPS and seeks comments on issues that should be included. This filing represents the Clean Coalition’s support for increasing the RPS to 50% by 2030 and notes that distributed energy resources will be needed to achieve this standard. The Clean Coalition urges improvements to the ReMAT, the procurement method best suited to small distributed energy resources. The Clean Coalition urges proper valuation of locational value. We note that Transmission Access Charges (TACs) are improperly assessed on all energy billed by utilities that are also transmission system owners, whether the energy used the transmission system or not. We urge the CPUC to coordinate with CAISO to correct this misapplication of TACs.

CPUC Energy Division: Green Tariff Shared Renewables (“GTSR”) Program | March 16, 2015
The Clean Coalition asserts that PG&E and SDG&E did not select the census tracts for the Environmental Justice component of the GTSR program properly. The Clean Coalition also asserts that all three utilities (PG&E, SDG&E and SCE) are not properly procuring for the GTSR program, in that they fail to plan for the utilization of the ReMAT procurement tool.

CPUC: NEM 2.0 | March 16, 2015
This filing represents the Clean Coalition’s comments on NEM 2.0. Through Rulemaking 14-07-002, the California Public Utilities Commission will develop a successor to the existing net energy metering (“NEM”) tariff for eligible customer-generators. On February 23, 2015, Administrative Law Judge Simon issued a ruling seeking comment on policy issues of the successor standard contract or tariff—encompassing both the statutory requirements set out in Pub. Util. Code 2827.1(b) and additional elements that are part of the overall administration of the program. In these comments, the Clean Coalition responds to a number of questions raised by the ruling, including issues concerning interconnection, disadvantaged communities, and sustainable growth of renewable distributed generation.

CPUC: PG&E Electric Vehicle Program Application | March 13, 2015
This filing represents the Clean Coalition’s recommendation that the extensive deployment of Electric Vehicles (“EVs”) proposed by PG&E be made in coordination with many planning proceedings, especially the distribution resources planning proceeding, in order to maximize the use of EVs as distributed energy resources (“DER”) to provide benefit to the grid. PG&E proposes extensive deployment of distribution infrastructure to support EVs; support of other DER, such as local renewables, should also be an objective of this distribution infrastructure investment, so that the investment is maximized. Infrastructure deployment should facilitate the interconnection of DER and reduce the costs of interconnection.

NY DPS: New York Standardized Interconnection Requirements | February 27, 2015
This filing represents the Clean Coalition’s informal comments on potential modifications to the Standardized Interconnection Requirements (“SIR”) proposed by the Department of Public Service (“DPS”). Our comments urged DPS to initiate a formal rulemaking to continue their efforts. Further, we offered lessons from our experience leading reform efforts of California’s Rule 21 interconnection tariff.

CPUC: Green Tariff Shared Renewables Program (SB 43) | February 17, 2015
This filing represents the Clean Coalition’s recommendations for issues that should be considered in Phase IV. Procurement mechanismsfor the Green Tariff Shared Renewables (GTSR) Program, especially through ReMAT, should be developed. We discuss mechanisms for ensuring locational value is evaluated as a benefit of GTSR projects. Incentives for procurement of the Environmental Justice (EJ) component should be considered. We continue to support the use of race/ethnicity in the selection of the EJ component.

CPUC: Green Tariff Shared Renewables Program (SB 43) | January 26, 2015
This filing represents the Clean Coalition’s recommendations retaining advanced procurement requirements for the Green Tariff Shared Renewables (GTSR) Program. We urge that the CPUC establish requirements that the IOUs utilize the ReMAT for GTSR procurement. We support use of race/ethnicity immediately in the selection of the Environmental Justice component of GTSR. We urge evaluation of avoided Transmission Access Charges and locational grid benefits of GTSR projects.

CPUC: Green Tariff Shared Renewables Program (SB 43) | January 20, 2015
This filing represents the Clean Coalition’s recommendations on the Proposed Decision. We urge that avoided Transmission Access Charges be recognized as a benefit of the Green Tariff Shared Renewables (GTSR) Program and should be credited to customers. The Clean Coalition urges that the statutory requirement that renewable energy resources be located in reasonable proximity to enrolled participants must be more explicitly and directly implemented by the IOUs. We urged the Commission to address issues in the selection of disadvantaged communities for the Environmental Justice component of the GTSR Program, in that certain regions are disproportionately represented by the current selection tool. The Clean Coalition supports consideration of race and ethnicity in the selection of disadvantaged communities.

CPUC: Long-Term Procurement Plan | January 12, 2015
This filing represents the Clean Coalition’s comments on the assigned ALJ’s nine-point plan concerning the integration and refinement of procurement policies and consideration of Long-Term Procurement Plans (“LTPPs”). The Clean Coalition generally supported the nine-point plan and provided brief comments on certain aspects of efforts to refine modeling practices by the CPUC.

2014

CPUC: Demand Response and Energy Efficiency potential for California | December 31, 2014
This filing represents informal joint comments to Energy Division regarding the methodology used in the 2015 California Energy Efficiency Potentials and Goal Study to determine baseline energy use for various energy efficiency measures, also applicable to Demand Response potential. Recommend attention to additional new potential when estimating effectiveness, and the addition of locational analysis to target higher effectiveness.

CPUC: Green Tariff Shared Renewables Program (SB 43) | December 18, 2014
The filing represents the Clean Coalition’s comments regarding changes to the Green Tariff Shared Renewables (GTSR) Program. The ALJ’s ruling sought from parties regarding changes to the Renewable Auction Mechanism (RAM) regarding the Green Tariff Shared Renewables (GTSR) Program. The Clean Coalition supports the use of the Renewable Auction Mechanism for procurement for the GTSR program. However, in order to meet requirements of the GTSR program (projects located close to enrolled participants, located in disadvantaged programs), the Clean Coalition urges that evaluation of benefits for the GTSR Program should include locational value. Regarding whether to use the renewable integration cost adder, we point out that it reflects a full accounting of the costs and benefits of a project; this cost adder should only be used if the locational value of a project is also evaluated.

CPUC: Distribution Resources Plans | December 12, 2014
This filing represents the Clean Coalition’s comments on Commissioner Michael Picker’s Draft Guidance for Use in Utility AB 327 (2013) Section 769 Distribution Resources Plans. Our comments strongly support the draft guidance and offer several suggestions for further improvement. The particular areas that we commented on to improve the Draft Guidance included DER growth scenarios, demonstration and deployment of DER, data access, future tariffs and contracts, integration capacity analysis, and net ratepayer benefits.

CPUC: NEM paired energy storage | December 2, 2014
This filing represents the Clean Coalition’s reply comments on Estimation Methodologies proposed by the ACR (for small solar NEM facilities), to limit NEM export to that which could be achieved by NEM-eligible generation. The Clean Coalition prefers Methodology #2, a monthly estimation of NEM generation (as opposed to an hourly estimation of NEM generation), as it allows more flexibility for the NEM facility to store energy for use in peak periods. The Clean Coalition also finds that either methodology is equally understandable.

CPUC: Advanced Inverter – Rule 21 Tariff standards | November 20, 2014
This filing represents the Clean Coalition’s reply comments pursuant to a request for comments on the Smart Inverter Working Group—Phase 2 Communications Protocols agenda for a workshop of October 27, 2014. We urged the Commission to consider cost impacts of advanced inverter communication features and accommodate alternatives where equipment or operational costs provide proportionately little or no additional benefit.

CPUC: NEM paired energy storage | November 20, 2014
This filing represents the Clean Coalition’s filed comments on Estimation Methodologies proposed by the Assigned Commissioner’s Ruling for small solar NEM facilities, to limit NEM export to that which could be achieved by NEM-eligible generation. Clean Coalition prefers Methodology #2, which is a monthly estimation of NEM generation. Compared to an hourly estimation of NEM generation, this option allows more flexibility for the NEM facility to store energy for use in peak periods.

FERC: CAISO Interconnection Reporting | November 13, 2014
This filing represents the Clean Coalition’s response to a California Independent System Operator (“CAISO”) filed motion with the Federal Energy Regulatory Commission requesting relief from the requirement to file interconnection queue quarterly progress reports. The Clean Coalition submitted this answer to CAISO’s motion, which supports the substantial improvements the CAISO has made to its interconnection and reporting procedures, but emphasizes that substantial issues remain. Our organization recommended modifying the reporting requirements to reduce the regulatory burden on CAISO, while improving access to important interconnection data.

CPUC: Integrated Demand-Side Resource Programs | November 7, 2014
This filing represents the Clean Coalition’s comments on the CPUC’s proposed regulatory framework for guiding, planning, and evaluating Integrated Demand-Side Resource Programs (currently known as the “Customer Energy Solutions Framework”). Our comments urged the Commission to consider three additional areas of focus in the proceeding: 1) locational value, 2) the additional benefits resulting from integrated use of multiple types of distributed energy resources, and 3) developing a market for distributed energy resources to monetize all grid services the resources are capable of providing.

CPUC: NEM 2.0 | October 20, 2014
This filing represents the Clean Coalition’s reply comments following a public workshop on a methodology known as the “Public Tool” that will test options for a successor to the existing net energy metering (“NEM”) tariffs. These comments responded to other groups’ opening comments and reemphasized our previous recommendations focused on incorporating locational value into the tool and aligning NEM 2.0 with AB 327’s requirement for utilities to develop Distribution Resources Plans.

CPUC: Distribution Resources Plans | October 6 ,2014
This filing represents the Clean Coalition’s recommendations on implementing the Distribution Resources Plans requirement of AB 327. These comments responded to other groups’ opening comments and reemphasized our previous recommendations for developing a methodology to determine optimal locations of distributed energy resources.

CPUC: NEM 2.0 | October 1, 2014
This filing represents the Clean Coalition’s comments following a public workshop on a methodology known as the “Public Tool” that will test options for a successor to the existing net energy metering (“NEM”) tariffs. The comments generally focused on incorporating locational value into the tool and aligning NEM 2.0 with AB 327’s requirement for utilities to develop Distribution Resources Plans.

CPUC: Rule 21 Storage Interconnection & Cost Certainty | September 26, 2014
This filing represents the Clean Coalition’s response to party comments on the CPUC staff proposals regarding Rule 21 Storage Interconnection & Cost Certainty issues. We address issues including the causes of uncertainty, the limited relevant impact of prior reforms, avoiding further delay in addressing these issues, and concerns regarding cost-shifting.

NY PSC: New York Reforming the Energy Vision (REV) | September 22, 2014
This filing represents the Clean Coalition’s comments on the New York Department of Public Service’s Straw Proposal for REV Track 1 Issues. Our comments urged the Commission to initiate a process of distribution grid planning. Our recommendations drew from our work on Distribution Resources Plans in California and the Hunters Point Project.

ACC: Tucson Electric Power’s proposed Utility-Owned Distributed Generation Program | September 16, 2014
This filing represents the Clean Coalition’s comments on the Utility-Owned Distributed Generation Program proposed by Tucson Electric Power Company in its 2015 Renewable Energy Standard Implementation Plan. Our comments generally supported the program as a worthwhile experiment that would address many barriers to proliferation of distributed renewable generation. We recommended comprehensive and open reporting requirements for the program, a transparent process of selecting solar installers, future modifications that would provide attractive opportunities for participation by commercial and industrial market segments, and that the program not replace Net Energy Metering programs.

CPUC: Rule 21 Storage Interconnection and Cost Certainty | September 12, 2014
This filing represents the Clean Coalition’s response to CPUC staff proposals regarding Rule 21 Storage Interconnection and Cost Certainty issues. The proposals were derived from Clean Coalition initiatives to address the highly uncertain cost risks interconnection applicants face even after an interconnection agreement is negotiated and signed. Recommendations are provided to strengthen the proposals, streamline the process, increase predictability, and reduce costs.

CPUC: Distribution Resources Plans | September 5, 2014
This filing represents the Clean Coalition’s offered recommendations on implementing the Distribution Resources Plans requirements of Assembly Bill (AB) 327. These recommendations included a methodology for determining optimal locations of distributed energy resources, and also urged the Commission to require each utility to deploy a pilot for at least one substation by year-end 2017 to demonstrate the Distribution Resources Plans.

NY PSC: PSEG Long Island Utility 2.0 Long Range Plan 2014 | August 29, 2014
This filing represents the Clean Coalition’s offered recommendations for designing and implementing a Community Microgrid for the South Fork to demonstrate the simultaneous deployment of significant local renewables and enhanced grid resilience: (a) selecting a single substation for the project, (b) considering substations in the South Fork with at least several thousand customers, (c) islanding only a few truly critical loads rather than the entire substation grid area, and (d) achieving the fully deployed Community Microgrid project by yearend-2016 before generous Federal tax benefits are set to expire.

CAISO: Storage interconnection | August 20, 2014
This filing represents the Clean Coalition’s comments on the energy storage facility interconnection tariff, including the following recommendations: 1) Modification to study criteria, screens and eligibility addressing storage, including when combined with generation and/or load. 2) Consideration of changes to Resource Adequacy market participation requirements (unbundling) for storage resources.

CPUC: NEM Successor Tariff/Contract | August 18, 2014
This filing represents the Clean Coalition’s offered comments on the Anticipated Activities and Preliminary Schedule set forth in the OIR.

CPUC: Advanced Inverter – Rule 21 Tariff Standards | August 18, 2014
The filing represents the Clean Coalition’s support for Rule 21 Tariff amendments to incorporate Advanced Inverter function standards, conditional upon the date for mandatory requirements allowing 18 months for market to accommodate and certify new products. We note the need to address potential revenue cost and compensation factors in association with mandatory Tariff requirements.

CPUC: Long Term Procurement Plan | August 4, 2014
This filing represents joint comments opposing the proposed CPUC decision to deny petitions to modify the SDG&E proposed procurement plan for replacing SONGS. Joint Comments assert that the CPUC should require a Tier III Advice letter for review and approval of SDG&E’s procurement plans or, in the alternative, require a 15 day formal notice and comment period prior to Energy Division approval.

CPUC: Demand Response | August 4, 2014
This Settlement Agreement facilitates the full monetization of demand response and setting firm goals relating to California system needs, including integrating higher levels of renewable energy.

NY PSC: New York Reforming the Energy Vision | July 18, 2014
This filing represents the joint comments of the Clean Coalition, the Alliance for Clean Energy New York, the Association for Energy Affordability, Columbia University Center for Climate Change Law, Environmental Advocates of New York, Environmental Defense Fund, Pace Energy and Climate Center, Natural Resources Defense Council, New York Public Interest Research Group and the Sierra Club. Comments focused on Outcomes for Reforming the Energy Vision (REV) proceeding, identify of Distributed System Platform Provider, Benefits and Costs of distributed energy resources (DERs), transitioning existing clean energy programs, enhanced services, and access to data. Joint comments support the comments of the Clean Coalition on the utility role in grid planning for DERs.

NY PSC: New York Reforming the Energy Vision | July 18, 2014
This filing represents the Clean Coalition’s comment on Reforming the Energy Vision, which is a unique opportunity to support New York’s clean energy, resilience, and economic goals by addressing structural biases against distributed energy resources (DERs). To accomplish fundamental and lasting change, the PSC should realign the roles, responsibilities, and optimization processes for transmission and distribution grid planning to meet state and local goals. The PSC should also clarify the roles of the distribution operators and the transmission operator to make it possible to realize the full value of DERs and reduce the operational complexity of managing DERs for meeting local and bulk system needs.

CPUC: LTPP SONGS/OTC replacement | June 23, 2014
This filing represents a petition by the Clean Coalition, NRDC and EDF to the CPUC to require SDG&E to file its proposal for replacing SONGS through an Advice Letter, giving stakeholders opportunity for formal comment and requiring CPUC approval for the proposed portfolio of resources.

CPUC: Energy storage IOU procurement plans | June 19, 2014
This filing represents the Clean Coalition’s workshop reply comments on Energy Storage IOU procurement plans. Our reply addresses standardization of Pro Forma Agreements, RFO deadlines, interconnection, eligibility, technology diversity, and standards for deferment of procurement targets.

CPUC: Energy storage IOU procurement plans | June 12, 2014
This filing represents the Clean Coalition’s workshop comments on Energy Storage IOU procurement plans. In particular, these comments address interconnection requirements, eligibility standards, technology diversity, evaluation protocols, and the cost effectiveness standards for deferment of procurement targets, including accounting for locational and other benefits.

SCP: Proposed feed-in tariff program | June 6, 2014
This filing represents the Clean Coalition’s workshop comments on initial straw proposal by Sonoma Clean Power (SCP) for a 5 MW (PV equivalent) Feed in Tariff proposal for all sources of local renewable energy. The Clean Coalition largely supports the straw proposal and offered economic analysis and refinements to improve program effectiveness by addressing fees, penalties, scheduling, site control, and milestones in informal comments and direct communication.

CPUC: NEM Successor Tariff/Contract | May 30, 2014
This filing represents the Clean Coalition’s informal comments on NEM 2.0 design. The successor program should be designed to increase participation of large commercial and multi-family properties. AB 327 requires NEM 2.0 pricing to be roughly equal to the value, and it also requires NEM 2.0 to support sustainable growth of customer-sited DG.  Facilitating participation of larger, less expensive DG would make it possible to increase the size of the pie while avoiding cost-shifting.

Oregon PUC: Value of Solar | May 24, 2014
This filing provides Clean Coalition comments on Oregon PUC report regarding Value of Solar and Oregon Solar Programs, submitted through local collaborator OREP.

CPUC: Demand Response Reply Testimony | May 22, 2014
This filing provides the rebuttal testimony of Stephanie Wang, Greg Thomson, and Charles Schoenhoeft on behalf of the Clean Coalition on Demand Response Rulemaking Phase 2 and 3 Issues, including demand response goals, optimal locations for demand response, and improved forecasting.

CPUC: Demand Response PD Reply | May 12, 2014
This filing provides Clean Coalition reply comments on the Proposed Decision approving Demand Response (DR) program and 2015-2016 bridge funding. Clean Coalition supports PG&E’s comments to restore funding for their DR pilot aimed at deferring transmission and distribution upgrades. We also argue that the Pilot will substantially contribute to distribution planning for all utilities, including that required by Assembly Bill 327.

CPUC: Demand Response Testimony of Stephanie Wang on Demand Response Goals | May 6, 2014
This filing provides Clean Coalition recommendations on future Demand Response goals.

CPUC: Opening Brief on Green Tariff Applications (SB 43) | May 2, 2014
This filing provides Clean Coalition recommendations that the methodology for calculating the costs and benefits of Southern California Edison’s Green Rate and Community Renewables programs include avoided new generation costs and locational value to maintain ratepayer indifference and meet the requirements of SB 43.

CPUC: SB 43 PG&E reply brief | April 9, 2014
The Clean Coalition supported inclusion of locational value and environmental justice mandate compliance in PG&E’s SB 43 programs.

CPUC: Clean Coalition Protest on Energy Storage Applications | April 7, 2014
This filing provides Clean Coalition protest on utility applications for Energy Storage for: clarification of the consistent evaluation protocol and the inclusion of all quantifiable transmission & distribution benefits in the CEP’s net market value calculations.

CPUC: Demand Response PD comments | March 13, 2014
This filing provides Clean Coalition’s opening comments on the Demand Response Bifurcation Proposed Decision. Comments focused on importance of not creating bias against load modifying demand response resources.

CPUC: SB 43 PG&E ELCR comments | March 7, 2014
This filing provides Clean Coalition comments on PG&E’s Enhanced Local Community Renewables Proposal.CEC: IEPR 2014 | March 4, 2014
This filing provides the Clean Coalition’s brief recommendations on the Electricity Update of the 2014 IEPR update.

CPUC: Clean Coalition Reply Comments on DGSP Proposed Decision – Rule 21 | March 4, 2014
In this filing, the Clean Coalition supports PG&E and SDG&E’s joint recommendation for cost contribution to be incorporated in cost assignment as well as additional recommendations on the Proposed Decision.

CPUC: Resource Adequacy (R.11-10-023) Flexible Capacity | March 3, 2014
This filing provides Clean Coalition reply comments on the staff proposal on the flexible capacity implemention framework including cost allocation, market efficiency, flexible capacity and bundling.

CAISO: Clean Coalition, NRDC, & EDF Comments on Draft 2013-2014 Transmission Plan | February 25, 2014
The Joint Parties offered recommendations to refine the Local Preferred Resources Assessment for the LA Basin and San Diego to better reflect the methodology set forth in the Straw Proposal, to model scenarios that rely on the minimum level of gas-fired generation required by the CPUC Long Term Procurement Plan, and to reach an optimal portfolio of resources to meet local reliability needs.

CPUC: Clean Coalition Amended Comments on Renewable Auction Mechanism (RAM) Re-authorization | January 31, 2014
This filing provides the Clean Coalition comments in support of reauthorization of minimum procurement levels to maintain the market, while also using RAM as a mechanism to procure energy to meet operational needs and policy goals. We propose that RAM projects be included in competition with bids in RPS and other RFOs where RAM projects meet the eligibility criteria.

CPUC: Clean Coalition Rebuttal Testimony on SB 43 | January 10, 2014
This filing provides Clean Coalition opening comments that the Commission 27 require utilities to use a procurement method suited for projects with a capacity of one 28 megawatt or smaller, tailored to allow Environmental Justice Projects to compete only against 29 other such projects and to reflect the interconnection needs specific to such projects.

CPUC: Clean Coalition’s Comments in Response to Questions from December 12, 2013 Workshop Questions in 2014 LTPP | January 8, 2014
This filing provides Clean Coalition comments that the Commission heed the recommendations of the NRDC. With respect to DR, we recommend that the Commission develop assumptions based on the potential to use DR as California reevaluates and redesigns its DR programs, rather than using past performance to set DR assumptions for the scenarios. The baseline scenarios should be adjusted to reflect at least the same pace of renewables adoption as the 2010-2020 period – 40% by 2024 and 50% by 2030 respectively. The High Preferred Resources scenarios should include more ambitious targets.

2013

CPUC: Clean Coalition Opening Comments on SB 1122 Implementation | December 20, 2013
This filing provides Clean Coalition opening comments on SB 1122 implementation, including recommendations to: Allow the bimonthly 5 MW allocation for each product category to be exceeded by up to 1 MW to better accommodate the size of queued projects and avoid unnecessarily delaying projects and program capacity allocation & request the CPUC implement a method to recognize transmission capacity usage costs to establish differential value to be reflected in a PPA price adjustment.

CPUC: Clean Coalition Reply Comments on SB 43 | December 20, 2013
This filing provides Clean Coalition recommendations on next steps for SB 43, including information incorporation from the Bayview-Hunters Point project in conjunction with PG&E.

CPUC: Clean Coalition Comments on Order Instituting Rulemaking | December 13, 2013
This filing provides Clean Coalition comments on the direction of the proceeding, and encouraging the expansion of electric vehicles.

CPUC: Clean Coalition Comments on Phase 2 Foundational Questions | December 13, 2013
This filing provides Clean Coalition comments and clarification on direction on the proposed bifurcation of the DR programs. We provide discussion on alternative definitions, which include local reliability vs. bulk system reliability.

CPUC: Clean Coalition Comments on Alternate Resolution E-4559 | November 27, 2013
This filing provides Clean Coalition support for the adoption of Alternate Resolution E-4559 rather than Resolution E-4559.

LA County: Planning & Zoning for Renewable Energy | November 26, 2013
This filing provides Clean Coalition joint comments with Sierra Club and Audubon Society on ordinance amending Title 22 – Planning and Zoning – of the Los Angeles County Code related to the establishment of regulations for small-scale renewable energy systems, objecting to restrictive definitions of wholesale DG, and recommending alternative language.

CEC: Electricity Infrastructure Costs of Distributed Generation | November 5, 2013
This filing provides Clean Coalition comments in response to the staff workshop: Electricity Infrastructure Costs of Distributed Generation.

CPUC: Resource Adequacy (R.11-10-023) Flexible Capacity – Use-limited resources | October 31, 2013
This filing provides Clean Coalition and DECA informal comments related to Treatment of Use-Limited Resources in the Draft Staff Proposal for Qualifying Capacity and Effective Flexible Capacity Calculation Methodologies for Energy Storage and Supply-Side Demand Response & Resources Adequacy Workshop (R.11-10-023).

CPUC: Informal comments on staff proposal re: Qualifying Capacity and Effective Flexible Capacity | October 22, 2013
This filing provides Clean Coalition and DECA informal comments on staff proposal, expressing some caution over the proposed probabilistic modeling methodology and urging a switch to “perfect resource” concept instead of “perfect generator”.

CPUC: Comments on Demand Response Rulemaking | October 21, 2013
This filing provides Clean Coalition comments on Demand Response Rulemaking and Scope of Proceeding.

CPUC: Clean Coalition Reply Comments on Energy Storage Proposed Decision | September 30, 2013
This filing provides the Clean Coalition’s reply comments on energy storage proposed decision.

CEC: Clean Coalition Comments on Preliminary Reliability Plan for LA Basin and San Diego | September 23, 2013
This filing provides Clean Coalition comments on the Preliminary Reliability Plan for the Los Angeles Basin and San Diego.

CPUC: Clean Coalition Opening Comments on Energy Storage Proposed Decision | September 23, 2013
This filing provides the Clean Coalition’s opening comments on energy storage proposed decision.

CPUC: Clean Coalition Opening Comments on Assigned Commissioner’s Ruling Regarding the Transfer of Responsibility for Collecting Solar Statistics from the California Solar Initiative | September 9, 2013
This filing provides the Clean Coalition’s guidance and recommendations on various data collection strategies for the California Solar Initiative and improving its relationship with Rule 21 interconnection procedures.

CPUC: Advanced (“smart”) Inverter Standards for Rule 21 Interconnection Tariff | August 30, 2013
This filing represents the Clean Coalition’s reply comments responding to other parties and reiterating our support for the adoption of standards without delay and further research to continue to support the value of advanced inverters.

CPUC: Advanced (“smart”) Inverter standards for Rule 21 interconnection tariff | July 31, 2013
This filing provides the Clean Coalition’s opening comments on proposed standards Advanced (“smart”) Inverter standards for Rule 21 interconnection tariff that the Clean Coalition participated in drafting. Comments support adoption of these standards without delay and provide background on the broad rationale and value of using Advanced Inverters.

CPUC: Rule 21 Interconnection Working Group on data reporting proposal | July 30, 2013
This filing represents the Clean Coalition’s reply to the Joint IOU Response from July 12, 2013. Following up on the Rule 21 Interconnection Settlement and ongoing successful efforts by the Clean Coalition to increase transparency in the interconnection process, the CPUC established a Working Group to recommend improvements in public data reporting and review of costs and tariff compliance for both Rule 21 and FERC jurisdictional Wholesale Distribution Tariffs in California.

CPUC: SONGS Replacement and Long-Term Procurement Proceeding | July 26, 2013
This filing represents the Clean Coalition’s joint letter to Governor Brown regarding the plan to replace the San Onofre Nuclear Generating Station (SONGS). The letter urges that the CPUC’s active public process in the Long-Term Procurement Plan (LTPP) proceeding is the best forum to determine how it will be replaced, and that the process should be transparent, utilize the thorough analyses already provided therein, and not result in construction of unneeded fossil-fueled power plants and transmission lines at the expense of public health, the environment, and customers.

CPUC: SCE Solar PV Program | July 24, 2013
This filing represents the Clean Coalition’s compensation claim for work contributed to two decisions made regarding Southern California Edison’s Solar Photovoltaic Program.

CPUC: Assigned Commissioner’s Ruling on Storage Procurement Targets | July 19, 2013
This filing represents the Clean Coalition’s reply comments to various parties’ opening comments regarding the Assigned Commissioner’s Ruling on storage procurement targets.

CPUC: SEIA Petition for Modification of SCE’s SPVP | July 10, 2013
This filing represents the Clean Coalition’s comments in general support of SEIA’s Proposal for Modification.

CPUC: Assigned Commissioner’s Ruling on storage procurement targets | July 3, 2013
This filing represents the Clean Coalition’s comments focused on an alternative procurement mechanism for storage projects; assuring cost-effectiveness but also providing market certainty; supporting some utility ownership of certain storage projects; and urging the Commission to provide further details regarding its proposed targets.

CPUC: Petition for Modification of SB 32 Final Decision | June 25, 2013
This filing represents the Clean Coalition’s Petition for Modification of the SB 32 Final Decision, requesting a number of factual corrections and one policy change of 5 MW to 6 MW for each bimonthly period in order to avoid the “stranded MW” problem associated with only 5 MW.

CAISO: Transmission Planning Process | June 19, 2013
This filing represents the Clean Coalition’s comments on the San Francisco Peninsula Extreme Event Reliability Assessment, emphasizing the opportunity for local generation and other non-transmission alternatives to improve reliability.

CPUC: Comments on Draft Resolution E-4593 | June 17, 2013
This filing represents the Clean Coalition’s brief comments on the draft resolution, reiterating our comments on the advice letter, that SB 380 eliminated the distinction between WATER and CREST programs, and that this is the preferred rationale for the correct outcome in the draft resolution.

CPUC: Flexible Capacity – Resource Adequacy Program | June 17, 2013
This filing represents the Clean Coalition’s comments supporting the Proposed Decision in finding no immediate need for additional capacity and emphasizing the importance of inclusion of preferred resources. The comments objected to the criteria limiting participation of many preferred resources and presented Clean Coalition modeling results demonstrating the potential value of Demand Response, Energy Storage, and Balancing Authority exchange.

FERC: Solar Energy Industries Association Petition for Rulemaking | June 3, 2013
This filing represents the Clean Coalition’s comments supporting the Federal Energy Regulatory Commission’s Notice of Proposed Rulemaking suggestions, with some modifications regarding content of the pre-application report and online reporting of interconnection applications. Modifications are designed to improve the Fast Track process as part of Small Generator Interconnection Procedures nation-wide.

CEC: 2013 IEPR – Transmission | May 21, 2013
This filing represents the Joint Comments of the California Consumers Alliance and the Clean Coalition regarding the Workshop on California and Western States Transmission Planning and Permitting Issues related to the Renewable Action Plan. The comments place emphasis on the need for improved analysis and coordination of planning to support non-transmission alternatives and avoid unnecessary transmission development.

CAISO: Demand Response and Energy Efficiency Roadmap Workshop | May 21, 2013
This filing represents the Clean Coalition’s comments on the scope and approach of CAISO’s planning for integration of Demand Response, operations and market development. Clean Coalition positions emphasize the potential for Distributed Generation + Demand Response to allow greatly increased levels of variable renewables at lower costs while reducing total capacity requirements.

CPUC: Alternate Proposed Decision Regarding SCE’s Solar PV Program | May 17, 2013
This filing represents the Clean Coalition’s reply comments criticizing the Alternate Proposed Decision’s lack of reliance on actual market data for judging Southern California Edison’s (SCE) assertions of cost savings, SCE’s lack of compliance with Clean Coalition request for actual data, and failure by CPUC to utilize the appropriate burden of proof.

CPUC: Long Term Procurement Plans | May 9, 2013
This filing represents the Clean Coalition’s Informal Comments on the Base Case recommending changes to include planned renewable capacity, reflect actual development, and recognize the flexibility provided by DG+IG solutions, including demand response and advanced inverter capabilities.

CAISO: Generation Interconnection Procedures | April 30, 2013
This filing represents the Clean Coalition’s comments on priority topics for 2013 Interconnection Process Enhancements for the ISO Generation Interconnection Procedures.

CPUC: Motion to Take Official Notice of Discovery Documents | April 25, 2013
This filing represents the Clean Coalition’s motion to have the CPUC take official notice of joint party discovery requests and utility responses, from Nov. 2012 to April 2013.

CPUC: Draft Small-Scale Bioenergy Report | April 24, 2013
This filing represents the Clean Coalition’s informal comments on various issues raised by Commission staff and the draft bioenergy report.

CPUC: PG&E Motion for Clarification re AB 1969 | April 24, 2013
This filing represents the Clean Coalition’s opening comments, opposing PG&E’s motion by recommending that the Commission eliminate any distinction between types of developers for AB 1969 programs, as the Commission has already done for SB 32.

CPUC: Flexible Capacity Procurement | April 15, 2013
This filing provides Clean Coalition Reply comments on flexible capacity and steps for moving forward with 2015 resource procurement.

CPUC: SB 32 Proposed Decision and Alternate Decision | April 15, 2013
This filing represents the Clean Coalition’s reply comments to various parties’ opening comments on the SB 32 Proposed Decision and Alternate Decision.

CPUC: SCE Advice Letter 2870-E (CREST PPAs) | April 15, 2013
This filing represents the Clean Coalition’s protest to Southern California Edison’s Advice Letter, recommending a policy route that ensures that the maximum of Distributed Generation Power Purchase Agreements are available under both AB 1969 and SB 32 Feed-in Tariff programs.

CAISO: DG Deliverability Allocation | April 10, 2013
This filing represents the Clean Coalition’s comments addressing limits on DG deliverability assignment and modification of new ISO program to comply with FERC requirement for “first come, first served”.

CPUC: SB 32 Proposed Decision and Alternate Decision | April 8, 2013
This filing represents the Clean Coalition’s opening comments on the Proposed Decision and Alternate Decision, supporting increasing tranche size to 10 MW, opposing rejection of our model PPA and making a number of other recommendations.

CPUC: Resource Adequacy Flexible Capacity Proposal | April 5, 2013
This filing represents the Clean Coalition’s comments focused on recommendations on the revised Flexible Capacity proposal from the CPUC Energy Division.

CPUC: Distribution Group Study Proposals in Rule 21 | March 22, 2013
This filing represents the Clean Coalition’s reply comments on DGSP proposals, responding to IREC and DRA opening comments.

CEC: 2013 IEPR | March 21, 2013
This filing represents the Clean Coalition’s comments focused on the inclusion of non-transmission alternatives and DG+IG in cost of generation considerations, as well as a more complete inclusion of locational value and resilience.

CAISO: Transmission Planning Process | March 14, 2013
This filing represents the Clean Coalition’s comments on the TPP study plan focused on non-transmission alternatives, consideration of programmatic solutions, additional policies to consider, and SONGS transparency.

CPUC: Opening Comments on PG&E Smart Grid Pilot Proposed Decision | March 7, 2013
This filing represents the Clean Coalition’s opening comments to PG&E’s application for a Smart Grid deployment pilot project. Generally, the comments supported the Proposed Decision and reiterate Clean Coalition support for Smart Grid pilot programs that call for the extensive use of DG+IG technology resources.

CPUC: SONGS Legal Issues | February 25, 2013
This filing represents the Clean Coalition’s opening legal brief responding to questions posed by the Commission. We argued that a hearing is not required for the Commission to reduce rates, and nor must the hearing, if held, be combined with the next General Rate Case, as SCE argued. We agreed, however, with SCE with the general proposition that the Commission may only reduce rates after the commencement of this Investigation, with one major exception in the event that the Commission finds any of SCE’s actions or omissions with respect to the SONGS outages to be unreasonable.

CPUC: Energy Storage Staff Report | February 21, 2013
This filing represents the Clean Coalition’s reply comments on interim staff report, generally supporting CESA’s opening comments but also urging equal attention on small-scale storage as well as large-scale storage; and criticizing SCE and PG&E’s “go-slow” approach.

CPUC: Energy Storage Staff Report | February 4, 2013
This filing represents the Clean Coalition’s comments on the interim staff report, calling for an interim energy storage procurement target, an evaluation period and then a more substantial target by 2020; designating GHG-reducing energy storage as a preferred resource; and properly quantifying the grid benefits of energy storage.

CAISO: Distributed Generation Deliverability Proposal | January 25, 2013
This filing represents the Clean Coalition’s opening comments supporting Option 1 and a “first expected online, first served” approach to awarded deliverability status, with suggested criteria for determining first expected online.

CEC: 2013 IEPR | January 24, 2013
This filing represents the Clean Coalition’s comments in support of some proposed elements of the 2013 IEPR and suggesting others to include.  Emphasis on climate change, non-transmission alternatives, and IG technology.

CAISO: Transmission Planning Process | January 22, 2013
This filing represents the Clean Coalition’s comments on 2013-2014 unified planning assumptions focused on the need for CAISO to take non-transmission alternatives seriously, based on the state’s Loading Order and FERC Order 1000.

CPUC: Reply Comments on LTPP Track 1 LCR Proposed Decision | January 22, 2013
This filing represents the Clean Coalition’s reply comments on other parties recommendations for modifications to the Final Decision on Local Capacity Requirements in Southern California, and we emphasize the use of DG, DR and ES in the Final Decision.

CPUC: NRDC/CC/SCCEC Joint Opening Comments on the LTPP Track 1 LCR | January 14, 2013
This filing represents the Clean Coalition’s joint comments on the Track 1 LCR for LTPP. General support for increased energy efficiency use.

CPUC: Opening Comments on LTPP Track 1 LCR Proposed Decision | January 14, 2013
This filing represents the Clean Coalition’s opening comments on the Track 1 LCR for LTPP, focusing on general support for the PD and emphasizing the use of ES, DR and WDG.

CPUC: Comments on TPP Renewable Portfolios | January 11, 2o13
This filing represents the Clean Coalition’s comments on TPP workshop materials and renewable portfolios as well as offering policy comments on TPP process. Comments also address the inclusion of NTAs in the TPP process.

2012

CPUC: IEPA Application for Rehearing | December 31, 2012
This filing represents the Clean Coalition’s comments in support of IEPA’s AFR, highlighting the need to either eliminate the new termination right for RPS contracts or to modify it substantially.

CPUC: PG&E’s Advice Letter 4161-E | December 31, 2012
This filing represents the Clean Coalition’s response objecting to delaying the time frame for deployment of solar shifted to the RAM program and urging inclusion of 1-3 MW projects.

CAISO: Transmission Planning Process (TPP) | December 26, 2012
This filing represents the Clean Coalition’s comments urging CAISO to fully comply with FERC Order 1000 and the state’s Loading Order in the TPP, particularly in the economic modeling that was the focus of the Dec. 7 workshop.

CPUC: Resource Adequacy | December 26, 2012
This filing represents the Clean Coalition’s comments on questions posed by the CPUC on a Joint Proposal by the utilities on procuring Flexible Capacity beginning in 2014.

CPUC: RPS Procurement Reform | December 12, 2012
This filing represents the Clean Coalition’s reply comments on ACR; responding to various parties opening comments, including PG&E, CalWEA and GPI.

CPUC: Opening Comments on Track 2 PD for LTPP | December 10, 2012
This filing represents the Clean Coalition’s opening comments and recommendations on the Proposed Decision.

CPUC: Reply Comments on Responses to SONGS OII | December 10, 2012
This filing represents the Clean Coalition’s reply comments to other parties opening responses to the Preliminary Scoping Memo on the SONGS Investigation.

CEC: Comments on Draft 2012 IEPR Update | December 3, 2012
This filing represents the Clean Coaltiion’s comments on the draft version of the 2012 IEPR Update, highlighting regional targets, RE zones, advanced inverters, and distribution system planning.

CPUC: Clean Coalition Comments on Order Initiating Investigation | November 30, 2012
This filing represents the Clean Coalition’s submission of comments on the preliminary scoping memo on the investigation of the SONGS unit. The Clean Coalition offered comments regarding the possibility of DG+IG replacing any or all SONGS capacity that does not come back online.

CPUC: Clean Coalition Reply Comments On Track 3 Rules | November 30, 2012
This filing represents the Clean Coalition’s reply comments supporting other parties call for reduction in GHG emissions, increased transparency and adherence to the State’s loading order policy.

CPUC: RPS Procurement Reform | November 20, 2012
This filing represents the Clean Coalition’s recommendation that Locational Benefits (LBs) be added to the Least Cost Best Fit (LCBF) procurement process for RPS projects. The key component of LBs should be Transmission Access Charges (TACs), as a proxy for actual LBs, and the LB quantification should be used in LCBF to help in rank ordering proposed projects.

LADWP: Proposed CLEAN | November 15, 2012
This filing represents the Clean Coalition’s comments strongly recommending that the 75 MW CLEAN program be returned to 150 MW as in earlier proposals; recommend a Volumetric Pricing Adjustment (VPA) mechanism be included for an upward increase in price as well as degression.

CPUC: Petition for Modification of D.12-05-035 | November 12, 2012
This filing represents the Clean Coalition’s Petition for Modification of the SB 32 Re-MAT decision, arguing a number of points but primarily that the proposed price discovery mechanism won’t work as planned b/c the available MW are simply too small for each utility – particularly SCE, which will probably have zero MW available by the time the SB 32 program goes live.

CPUC: Rule 21 Reform | October 29, 2012
This filing represents the Clean Coalition’s revised comments on amended scoping memo, setting forth an alternative schedule and commenting on the scope of Phase II.

CPUC: RPS RFO decision | October 29, 2012
This filing represents the Clean Coalition’s comments in support of SCE’s decision to not hold an RPS RFO in favor of relying on WDG programs, but highlighting the need to dramatically expand WDG programs if SCE is to rely on them to meet the renewables net short for 2017-2020.

CPUC: Reply Comments on Joint LTPP/Storage Workshop Questions | October 23, 2012
This filing represents the Clean Coalition’s reply comments on other parties’ responses to ALJ ruling of 9/14/12. These comments detailed parties’ideas on how procurement processes can better incorporate preferred resources as well as non generation resources such as energy storage.

CPUC: Response to Megawatt Storage Farms Motion to Include Energy Storage at the Top of the Preferred Loading Order | October 22, 2012
This filing represents the Clean Coalition response to the motion by Megawatt Storage Farms written in conjunction with the California Environmental Justice Alliance (CEJA) provides reasoning and support for the inclusion of energy storage in the preferred loading order behind demand response and energy efficiency.

CPUC: Reply Comments on LTPP Scenarios | October 19, 2012
This filing represents the Clean Coalition’s comments on other parties’ initial comments on revised LTPP scenarios from the CPUC Energy Division and providing recommendations for the Commission’s consideration.

CPUC: LTPP Track 1 | October 12, 2012
Response to Opening Briefs in the LTPP track 1 proceeding, pertaining to use of Preferred Resources to meet LCR, consideration of Energy Storage, and opportunities for WDG to avoid transmission constraints.

CPUC: Amendments to CREST | October 12, 2012
This filing represents the Clean Coalition’s comments requesting key changes to interconnection policies and studies in SCE’s stalled CREST FIT program.

CPUC: LTPP/Storage Workshop Comments | October 9, 2012
This filing represents the Clean Coalition’s response to questions raised in regard to questions posed by the ALJ on procurement for non-generating resources.

CPUC: LTPP Scenario Policy Comments | October 5, 2012
This filing represents the Clean Coalition’s policy comments on the LTPP Proposed Scenarios for 2012.

CPUC: Additional Comments on LTPP Scenarios | September 10, 2012
The filing represents the Clean Coalition’s additional technical comments on the LTPP Proposed Scenarios for the 2012 proceeding.

CPUC: SB 32 PPA and Tariff | September 10, 2012
This filing represents the Clean Coalition’s reply comments on IOU proposed PPA and tariff. We argued again for adopting our Model PPA rather than the IOU PPA and responded to various party comments, as well as made some new comments on the proposed IOU tariffs.

CPUC: Technical Comments on LTPP Scenarios | September 7, 2012
This filing represents the Clean Coalition’s technical comments on the LTPP Proposed Scenarios for the 2012 proceeding.

CPUC: PG&E’s Request to Modify RAM Decision | September 5, 2012
This filing represents the Clean Coalitin’s advice letter to ED detailing the Coalitions’s position on PG&E’s request to modify decision.

CPUC: Rule 21 Comment | September 4, 2012
This filing represents the Clean Coalition’s coments offering its general support for the first phase in the Rule 21 settlement with several suggestions as to how the Commission should proceed and with the specific recommendation that the original schedule for the second phase should be adhered to.

CPUC: SCE’s Petition for Modification of Decision12-12-035 (SPVP) | August 24, 2012
This filing represents the Clean Coalition’s comments on SCE’s petition to modify the SPVP program.

CPUC: Rule 21 Interconnection Procedures | August 21, 2012
This filing represents the Clean Coalition’s reply comments on Distribution Group Study Process, highlighting some differences from other parties’ opening comments.

CPUC: SB 32 PPA and Tariff | August 15, 2012
This filing represents the Clean Coalition’s comments on IOU proposed PPA. We also proposed a Model PPA of our own, along with a number of critiques of the IOU PPA. Our main critique is that the proposed PPA is five times longer than the existing PPA.

CAISO: Flexible Capacity Procurement | August 13, 2012
This filing represents comments regarding CAISO proposal for authority to provide temporary financial incentives for retiring flexible capacity facilities to remain available until sufficient replacement capacity is on line. We support the proposal while adding protection against over procurement or subsidies that will inhibit market support for renewable alternatives.

CPUC: Clean Coalition Compensation Claim | August 7, 2012
This filing represents opening comments on the Proposed Decision. We requested leeway to remedy the lack of an NOI for R.08-08-009 and made a number of arguments in favor of a finding of substantial contribution on various issues.

CPUC: Southern California Edison Advice 2759-E | August 1, 2012
This filing represents the Clean Coalition’s comments on various changes that Southern California Edison wished to make on their submitted Petition for Modification (PFM) adopting changes to the Renewable Auction Mechanism (RAM).

CPUC: Rule 21 Interconnection Procedures | July 31, 2012
This filing represents opening comments on proposed Distribution Group Study Process (DGSP). The Clean Coalition supported PG&E’s proposal over SCE’s and requested more details on many issues, as well as removed “engineering judgment” as guidance.

CPUC: Energy Storage | July 30, 2012
This filing represents reply comments reminding parties that possible procurement targets for energy storage are included in the original legislation creating the energy storage proceeding.

CPUC: Energy Storage | July 20, 2012
This filing represents opening comments on proposed decision. We support the decision’s approval of the Energy Storage Analysis Framework and suggest further refinements for Phase II of the proceeding.

CPUC: Local Reliability Track (Track 1) of Long Term Planning Procurement (LTPP) | June 25, 2012
This filing represents the Clean Coalition’s comments on resource adequacy/flexible capacity, demand response, energy storage and reliability/capacity needs in Southern California.

CEC: Comments on CEC Integration Workshop | June 18, 2012
This filing represents the Clean Coalition’s comments addressing the need for advanced forecasting and energy storage to mitigate challenges of integrating renewables into a fossil fuel energy system.

CEC: The Clean Coalition Comments on June 22nd, 2012 Lead Commissioner Workshop on Electricity Infrastructure Issues in California | June 16, 2012
This filing represents the Clean Coalition’s  comments on the inclusion of IG solutions for the upcoming IEPR as well as offering recommendations on what the workshops should include in the future.

CAISO: FERC Order 1000 | June 15, 2012
This filing represents Clean Coalition’s comments asking the CAISO to discuss its plans to address FERC Order 1000 guidance to explore non-transmission alternatives.

CPUC: PG&E Smart Grid Pilot | June 13, 2012
This filing represents the Clean Coalition’s comments addressing points made in opening testimony regarding the need for smart grid technology.

CEC: Comments on CEC Finance Workshop | June 13, 2012
This filing represents the Clean Coalition’s comments underscoring the importance of certainty and low-risk contracts in aquiring financing for renewables.

CPUC: Resource Adequacy | June 11, 2012
This filing represents the Clean Coalition’s comments addressing standards for resource adequacy and emphasizing the need for clear rules on including energy storage and demand response in planning.

CPUC: The Clean Coalition’s Reply Comments on Straw Proposal on 2012 LTPP Standards | June 11, 2012
This filing represents the Clean Coalition’s comments on planning assumptions, deliverability and RPS goals.

CEC: Comments on CEC Jobs Workshop | June 6, 2012
This filing represents the Clean Coalition’s comments emphasizing the jobs that can be created by keeping energy production in-state.  Citing of Kammen’s findings on the employment benefits of CLEAN Programs.

CPUC: SCE Motion Regarding the Sunset of AB 1969 program | May 26, 2012
This filing represents Clean Coalition’s comments on SCE’s motion for additional clarity on the sunset of the AB 1969 feed-in tariff program; Clean Coalition supported the need for more clarity but disagreed with SCE’s suggestion that the contract signing deadline be June 30, 2012. Rather, Clean Coalition recommended that new AB 1969 applications be allowed until the Commission approves the new SB 32 PPA.

CEC: Comments on CEC Interconnection Workshop | May 21, 2012
This filing represents the Clean Coalition’s comments on the need for certainty in interconnection costs and timelines, rate-basing of distribution grid upgrades, and greater visibility into information that is currently protected by confidentiality rules.

CEC: Comments on CEC Geographic Areas Workshop | May 17, 2012
This filing represents the Clean Coalition’s comments in support of the California Energy Commission’s (CEC’s) newly proposed soft targets for the 12,000 Megawatts (MW) distributed generation DG goal.

CPUC: SB 32 Proposed Decision | April 23, 2012
This filing represent Clean Coalition’s reply comments on the March 20, 2012 Proposed Decision implementing SB 32, critiquing or supporting other parties’ opening comments.

CAISO: Deliverability of DG draft final proposal | April 12, 2012
This filing represents the Clean Coalition’s comments supporting the development of CAISO’s proposal for Deliverability of DG with proposed modifications on base case, COD timelines and allocation timelines.

CPUC: RAM PPAs | April 9, 2012
This filing represents the Clean Coalition’s arguments in opposition to proposed PPA language which would allow “unilateral termination right for Buyer in the event that expected ratepayer reimbursed transmission system upgrade costs increase by more than 10% over estimates provided by Producer when it bid into the solicitation.”

CAISO: Cost Allocation | March 29, 2012
This filing represents the Clean Coalition’s comments supporting the proposal on cost allocation principles but highlighting issues with clarity in definition and application, particularly related to cost causation, simplicity, equal treatment, and recommending boundaries limiting application from distribution connected projects that do not seek ISO services.

FERC: SEIA Petition for Rulemaking | March 27, 2012
This filing represents the Clean Coalition’s comments supporting the SEIA Petition for Rulemaking, to modify the 15% SGIP penetration screen, and to suggest an expanded scope for the new rulemaking.

CAISO: FERC Order 1000 | March 26, 2012
his filing represents the Clean Coalition’s comments on CAISO compliance with FERC Order 1000 transmission planning requirements and corrective measures emphasizing mandated consideration of non-transmission alternatives, attention to public policy goals, cost allocation, and inclusion of CPUC “high DG” planning scenario when evaluating transmission requirements.

CAISO: Generator interconnection procedures | March 23, 2012
This filing represents the Clean Coalition’s comments which focus on increased queue transparency and the importance of fixing Fast Track and ISP.

CPUC: Clean Coalition Comments on the Smart Grid Deployment Plan Workshop | March 15, 2012
This filing represents the Clean Coalition’s opening comments in response to Staff’s Comments and recommendations based on the Smart Grid Deployment Plan Workshops.

CAISO: Deliverability determination for DG, straw proposal | March 13, 2012
This filing represents the Clean Coalition’s comments supporting the development of CAISO’s proposal for Deliverability of DG and calling for correction of base case and  expansion of eligibility and allocation.

CAISO: Transmission Planning Process Draft Study Plan | March 13, 2012
The filing represents the Clean Coaltion’s brief comments calling for use of all four CPUC defined scenarios for comparative study outcomes, especially the “high DG scenario” for more realistic planning.

CPUC: SB 32 Joint IOU PPA | March 5, 2012
This filing represents the Clean Coalition’s comments on the initial proposed Standard Form Contract, propounded by the Joint Investor-Owned Utilities for the Section 399.20 Feed-In Tariff Program. The comments are in the form of Redline marks on the contract.

CEC: Comments on 2011 IEPR Final Report | February 21, 2012
This filing represents the Clean Coalition’s comments that acknowledge the tremendous work done by CEC in developing IEPR, but notes that several core assumptions in analyses must be revisited in the 2012 IEPR update.  Urgent outstanding issues include: regional target methodology for 12 GW DG goal, bias towards central station renewables, and the need to integrate energy policy silos.

CPUC: Opening Comments on Proposed Decision Implementing Assembly Bill 1954 | February 6, 2012
This filing represents the Clean Coalition’s comments regarding the proposed decision on Assembly Bill 1954. The filing provides support to the proposed decision with one exemption.

CPUC: SCE’s Petition for Modification of Decision 09-06-049 | January 31, 2012
This filing represents the Clean Coalition’s objections to the Proposed Decision supporting Southern California Edison’s (SCE) proposed cancellation of the SPVP solar rooftop WDG program and transfer of remaining 250 MW allocation to RAM.  SCE claimed unsubstantiated and grossly exaggerated ratepayer savings and failed to consider the loss of program benefits.

CPUC: Response to SCE’s petition for modification of the RAM decision | January 16, 2012
The filing represents the Clean Coalition’s objections to SCE’s assertion that the federal Critical Infrastructure Information Act applies to the information at issue in the RAM decision (D.10-12-048).  Namely, the Act simply doesn’t apply unless information is first submitted voluntarily to the Dept. of Homeland Security.

CAISO: Deliverability determination for DG, CAISO straw proposal | January 5, 2012
This filing represents the Clean Coalition’s comments on a straw proposal by CAISO prior to development of a formal proposal for determination of guaranteed deliverability of energy from Distributed Generation facilities.  Clean Coalition supports the proposed for simplified determination and allocation of capacity by Local Resource Agencies, but disagrees with restricting consideration to low base case capacity scenarios where these are being exceeded in practice.

2011

CEC: Draft 2011 Integrated Energy Policy Report (IEPR) | December 23, 2011
This filing represents the Clean Coalition’s comments on the draft 2011 IEPR before the final report is released.

CAISO: Business Process Manual for Generator Interconnection Procedures  December 12, 2011
This filing represents the Clean Coalition’s comments on the CAISO Business Process Manual, which is a non-tariff document used to determine the implementation of tariffs (in this case the Generator Interconnection Procedures).  The comments request more date tracking to ensure tariff deadlines are being met.

CPUC: Draft Staff Proposal for Implementation of SB 32 | November 14, 2011
This filing represents the Clean Coalition’s reply comments on the CPUC’s staff proposal for the implementation of SB 32.  To help CPUC staff craft a proposed decision, the comments provide legal interpretations of market price and avoided costs.  Additionally, the filing rebuts numerous comments from other parties, especially pricing comments from the IOUs.

CPUC: Southern California Edison’s Solar Photovoltaic Program | November 7, 2011
This filing represents the Clean Coalition’s comments on Southern California Edison’s (SCE’s) petition for modification of Decision 09-06-049.  The Clean Coalition observed that SCE’s proposed modifications will effectively kill the Solar Photovoltaic Program (SPVP) and/or the procurement of rooftop solar from Independent Power Producers in SCE territory.

CPUC: Senate Bill 32 Implementation | November 2, 2011
This filing represents the Clean Coalition’s numerous suggestions regarding the Senate Bill 32 (SB 32) staff proposal.  These comments include not requiring a completed Phase 1 interconnection study as a pre-condition for an SB 32 application, opposing Southern California Edison’s (SCE’s) pricing recommendations, and recommending the Clean Coalition’s degression/price increase schedule based on the level of interest in the program (volumetric degression).

CPUC: California Renewable Energy Small Tariff Reform | October 31, 2011
This filing represents the Clean Coalition’s comments regarding the Proposed Decision for the California Renewable Energy Small Tariff (CREST) Reform.  The Clean Coalition suggests minor changes to the Proposed Decision, which are almost uniformly favorable to the Clean Coalition’s requests in its motion for CREST reform, whereby changes to the existing CREST 1.5 megawatt (MW) CLEAN Contract were recommended in order to make it financeable.

CPUC: Order Instituting Rulemaking in New Rule 21 Proceeding | October 26, 2011
This filing represents the Clean Coalition’s comments regarding various macro issues relating to distribution grid interconnection reform under Rule 21.  This filing stresses the need for reform to meet the Governor Jerry Brown’s 12,000 megawatts (MW) of Distributed Generation (DG) goal.  These comments also discuss the need to have greater transparency and comprehensive information for all parties in order to better understand and resolve the state of California’s energy issues.

CAISO: Generator Interconnection Procedures Phase 2 (GIP 2) | October 7, 2011
These comments from the Clean Coalition discuss the Generator Interconnection Procedures Reform 2 (GIP 2) draft tariff language.  The comments focus primarily on modifying Fast Track timelines to reflect the fact that Fast Track is not working properly and therefore there is no need to delay before going to supplemental review.

CEC: Integrated Energy Policy Report | October 5, 2011
These are the Clean Coalition’s comments regarding the CEC’s draft report Renewable Power in California: Status and Issues.  The Clean Coalition believes Wholesale Distributed Generation (WDG) should be more heavily represented in the CEC’s action plan for renewable energy in California to reach Governor Brown’s goal of 12,000 MW of distributed generation by 2020.  Regional targets for meeting the governor’s goal should be based on load and adjustments should be made for special policy objectives.  Also, it is imperative that California modernizes its electricity and interconnection system by working towards Interconnection 3.0 and an Intelligent Grid.

CPUC: Senate Bill 32 Implementation | August 26, 2011
This filing represents the Clean Coalition’s most recent comments regarding SB 32’s implementation, with a particular focus on the three major Investor Owned Utilities’ (IOUs’) proposals for the Program.  The Clean Coalition recommended a number of changes to utilities’ proposed CLEAN Contract rates and Power Purchase Agreements (PPA).  The one clear conclusion is that the proposed PPAs are far too complex as they are replications of PPAs for much larger projects with excessive terms and conditions that are certainly not relevant to relatively small Wholesale Distributed Generation (WDG) projects.  Such complexity would defeat a primary benefit of enacting CLEAN Programs – simplicity in contracts and pricing.  In addition, this filing expresses the Clean Coalition’s support for the Interstate Renewable Energy Council’s proposal to rate base certain distribution grid upgrades.  It also states the Clean Coalition’s opposition to the Division of Ratepayers Advocates’ suggested Default Load Aggregation Point plus Renewable Energy Certificate pricing (from the net surplus metering decision, D.11-06-016) as inapplicable to SB 32.

CPUC: California Renewable Energy Small Tariff (CREST) Program Changes | August 15, 2011
This Motion asks the California Public Utilities Commission (CPUC) to require Southern California Edison (SCE) to make specific amendments to the currently available California Renewable Energy Small Tariff Power Purchase Agreement (CREST PPA).  These changes should take effect immediately so that projects can move forward in time to take advantage of federal tax benefits that are expiring at the end of 2011.

CPUC: Rule 21 Interconnection Procedures | July 26, 2011
The Clean Coalition protested the utilities’ request to allow Federal Energy Regulatory Commission (FERC)-jurisdictional interconnection procedures to be used on an interim basis under the state-jurisdictional Rule 21 interconnection process.  The Clean Coalition’s concerns are: 1) the FERC-jurisdictional procedures (Wholesale Distribution Access Tariff [WDAT]) are very lengthy and costly; 2) allowing this change on an interim basis opens the door wide for permanent use in the same way, which is very unwelcome; and, 3) the public utilities commission (PUC) should instead work quickly to revise Rule 21 and provide a viable interconnection procedure before the next cluster window closes for WDAT.

CPUC: Senate Bill 32 Implementation | July 21, 2011
These are the Clean Coalition’s opening comments on the administrative law justice Ruling regarding SB 32 (3 MW CLEAN Program) implementation. The Clean Coalition recommends a three-phase implementation process in which immediate pricing begins at Market Price Referent plus Time of Delivery.  In the second phase, pricing is proposed to include a rough proxy for Locational Benefits that is based on the avoidance of Transmission Access Charges (TACs).  In the third and final phase, the Locational Benefits adder is refined to be more precise.  The Clean Coalition also proposes the name “Volumetric Market Price” as a new term for pricing under this new program.

CAISO: Generator Interconnection Procedures Phase 2 (GIP 2) | July 14, 2011
These are the Clean Coalition’s final comments on the Generator Interconnection Procedures Reform 2 (GIP 2) before the proposal goes to the CAISO board for approval.  The Clean Coalition mainly reiterated its comments from prior submissions, continuing to stress the importance of queue and grid transparency.

CPUC: California Renewable Energy Small Tariff (CREST) Program Changes | June 22, 2011
The Clean Coalition submitted comments on various aspects of the proposed new pro forma Power Purchase Agreement (PPA).  Our main concerns were that Southern California Edison (SCE) move quickly to correct obvious problems in the existing PPA and not to impose any additional onerous requirements, such as Full Capacity Deliverability.

CAISO: Generator Interconnection Procedures Reform 2 (GIP 2) | June 10, 2011
The Clean Coalition’s additional comments on the Generator Interconnection Procedures Reform 2 (GIP 2).  GIP 2 is meant to address work unfinished from the CAISO Small Generator Interconnection Procedures (SGIP) reform.  Our comments have generally focused on increasing the CAISO’s grid and queue transparency.

CPUC: Order Instituting Rulemaking in new Renewable Portfolio Standard proceeding (R.11-05-005) | June 2, 2011
These are the Clean Coalition’s opening comments on the initial document kicking off this new proceeding.  Our comments focused on the need to rapidly implement SB 32 as part of this proceeding, RPS compliance issues and tradable Renewable Energy Certificate issues.

CPUC: Rule 21 Interconnection Procedures | May 31, 2011
The Clean Coalition comments following Rule 21 Workshop on April 29th, 2011 relating to CPUC jurisdictional practices for interconnection to the distribution grid.  The Clean Coalition has been actively advocating for revision of these rules to improve efficient and predictable access for wholesale distributed generation (WDG).  Our comments detailed existing barriers and offered specific recommendations for data availability and revision of the project screening and study processes.

FERC: PG&E Interconnection Procedures – Wholesale Distribution Access Tariff (WDAT) | May 30, 2011
The Clean Coalition Request for Rehearing of FERC order conditionally accepting PG&E’s proposed interconnection procedure changes for the Wholesale Distribution Access Tariff (WDAT). The Clean Coalition argued that FERC failed to enforce the stricter standards for improvement of procedures applicable to this proceeding, made important factual errors, and failed to address critical concerns commonly identified by the CPUC, the Clean Coalition, and other established parties.

FERC: SCE Interconnection Procedures – Wholesale Distribution Access Tariff (WDAT) | May 30, 2011
The Clean Coalition Request for Rehearing of FERC order conditionally accepts Southern California Edison’s proposed interconnection procedure changes for the Wholesale Distribution Access Tariff (WDAT). The Clean Coalition argued that FERC failed to enforce the stricter standards for improvement of procedures applicable to this proceeding, made important factual errors, and failed to address critical concerns commonly identified by the CPUC, the Clean Coalition, and other established parties.

CEC: Workshop on Renewable, Localized Generation | May 23, 2011
The Clean Coalition response to CEC staff questions following a workshop under the CEC’s Integrated Energy Policy Report (IEPR) to address the Governor’s goal of 12,000 megawatts (MW) of distributed generation by 2020. Issues included interim and regional targets, infrastructure capacity, implementation incentives, and specific programmatic recommendations. Drawing from the CEC commissioned KEMA study of European high PV penetration experience, we see no physical limits to 12,000 MW, but existing market barriers and available remedies.

CPUC: Project Viability Calculator (PVC) | May 20, 2011
Clean Coalition comments on the Energy Division’s request for comments on the Project Viability Calculator (PVC) for use in the Renewables Portfolio Standard (RPS) Solicitations.  The Clean Coalition argued that the current PVC does not accurately reflect project viability and that this is especially problematic given the unofficial use of these scores as predictive tools.

CAISO: Generator Interconnection Procedures Reform 2 (GIP 2) | May 6, 2011
Comments on the Straw Proposal for CAISO’s Generator Interconnection Procedures Reform 2 (GIP 2) following the initial stakeholder working groups.  GIP 2 is an effort to address issues identified by the Clean Coalition and other parties in the 2010 Small Generator Interconnection Procedures (SGIP) reform but not addressed due to schedule constraints.  Our issues include accessibility of interconnection data both for applicant planning and procedural review, improved Fast Track procedures, optional deliverability certification, and alignment with RAM program applicant requirements.

CPUC: Expedite 2011 Renewable Portfolio Standards (RPS) and Renewable Auction Mechanism (RAM) Programs Without Delays | May 4, 2011
The Clean Coalition and the Solar Developers Council submitted a letter urging the California Public Utilities Commission (CPUC) to assure that the 2011 Renewable Portfolio Standards (RPS) and Renewable Auction Mechanism (RAM) programs are expedited without any delays.  Some groups are encouraging the Commission to put off the 2011 RPS and RAM programs, yet by continuing on the current timeframe, the Commission can encourage job creation, create an environment of certainty for clean energy developers, and attract Wholesale Distributed Generation (WDG) projects. Such projects will fully benefit utilities, developers, and ratepayers.

CPUC: AB 1613 Combined Heat & Power, Rule 21 Interconnection, WDAT – Wholesale Distribution Access Tariff, PG&E, Qualifying Facility (QF) interconnection | March 31, 2011
Clean Coalition comments on PG&E QF Interconnection Proposal to substitute FERC governed WDAT interconnection procedures in place of CPUC governed Rule 21 procedures for combined heat and power facilities (CHP) pending update of Rule 21 at a future date.

FERC: PG&E Interconnection Reform | March 23, 2011
Protest of PG&E Interconnection proposal, highlighting the unreasonable length of the proposed new process and the inadequacy of the “accelerated options” proposed to mitigate this length.

CPUC: Senate Bill 32 Implementation | March 22, 2011
Reply comments on various implementation issues relating to SB 32.

FERC: SCE Interconnection Reform | March 22, 2011
Protest of SCE Interconnection proposal, highlighting the unreasonable length of the proposed new process and the inadequacy of the “accelerated options” proposed to mitigate this length.

CEC: RPS Net Short Calculations Method and Inter-Agency Standards | March 18, 2011
Methods and inter-agency standards for coordination of consistent RPS Net Short calculation – review and comments.

CPUC: Renewable Auction Mechanism (RAM) | March 17, 2011
Various comments on program deals of the new Renewable Auction Mechanism, the CPUC’s preferred program for all WDG 20 MW and below; the Clean Coalition highlighted concerns about deliverability requirements and various other issues.

CAISO: Generator Interconnection Procedures Reform 2 (GIP 2) | March 11, 2011
Initial comments on the Generator Interconnection Procedures Reform 2 (GIP 2).  GIP 2 is meant to address work unfinished from the CAISO Small Generator Interconnection Procedures (SGIP) reform.

CPUC: SB 32 Implementation | March 7, 2011
Opening brief on various implementation issues relating to SB 32, the expansion of the AB 1969 feed-in tariff; key issues are expansion to 5 MW; expansion of the program beyond the 750 MW first tranche; and resolution of ongoing WDG interconnection issue.

SCE: Wholesale Distribution Access Tariff (WDAT) Reform | February 14, 2011
Final comments on the SCE’s preliminary tariff to be filed with the Federal Energy Regulatory Commission (FERC) for WDAT (Wholesale Distribution Access Tariff) interconnection reform.

PG&E Wholesale Distribution Access Tariff (WDAT) Reform | February 8, 2011
This submission focuses on PG&E’s WDAT reform, which PG&E has launched as a result of the California Independeent System Operator’s (CAISO) Generator Interconnection Procedure (GIP) reform.

CPUC: Long Term Procurement Proceeding (LTPP) Integration Modeling | January 26, 2011
Reply comments on third workshop in Phase I of the LTPP, on technical integration modeling issues.

CPUC: Independent Process Audit of Utilities’ Interconnection Procedures | January 18, 2011
Letter calling for an independent process audit of utilities’ interconnection procedures.

2010

PG&E: Wholesale Distribution Access Tariff (WDAT) | December 22, 2010
This submission focuses on PG&E’s WDAT reform, which PG&E has launched as a result of the California Independeent System Operator’s (CAISO) Generator Interconnection Procedure (GIP) reform.

SCE: Wholesale Distribution Access Tariff (WDAT) and Generator Interconnection Procedure (GIP) reform | December 22, 2010
Comments on the preliminary tariff to be filed with the Federal Energy Regulatory Commision (FERC) for WDAT interconnection reform.

CPUC: San Diego Gas & Electric’s Solar PV Program | December 21, 2010
FITC comments on San Diego Gas & Electric’s Solar PV Program, with specific commentary around their Grid Transparency plans.

CPUC: San Diego Gas & Electric’s Solar PV Program | December 21, 2010
FITC comments on San Diego Gas & Electric’s Solar PV Program, with specific commentary around their Grid Transparency plans.

CPUC: Long Term Procurement Proceeding (LTPP) Integration Modeling | November 22, 2010
FITC comments on integration modeling and initial RIM model results.

CPUC: Tradable Renewable Energy Credits (TRECs) | November 19, 2010
Comments on the Alternate Proposed Decision on Tradable Renewable Energy Credits.

CPUC: PG&E Solar PV Program | November 15, 2010
FITC reply comments on various issues raised by parties in opening comments.

SCE: Wholesale Distribution Access Tariff (WDAT) | November 12, 2010
This submission focuses on SCE’s WDAT reform, which SCE has launched as a result of the CAISO’s proposed modifications to the SGIP.

CPUC: PG&E Solar PV Program | November 9, 2010
FITC comments comments on various issues raised by parties in opening comments.

SCE: Wholesale Distribution Access Tariff (WDAT) | October 25, 2010
This submission focuses on SCE’s WDAT reform, which SCE has launched as a result of the CAISO’s proposed modifications to the SGIP.

CPUC: Renewables Auction Mechanism (RAM) | September 27, 2010
Extensive opening comments on the proposed decision for a new auction program focused on 20 MW and under projects.

CPUC: Long Term Procurement Proceeding (LTPP) | September 21, 2010
Two integration models were presented in workshops and parties were asked a number of questions comparing the two models. We submitted fairly general comments about overarching issues.

CAISO: No Elimination of Small Generator Interconnection Procedures (SGIP) – 2 | September 7, 2010
The second letter addressed to the CAISO Board of Governors emphasizing that the Small Generator Interconnection Procedures (SGIP) proposal was flawed and would likley face rejection at FERC. Over 100 parties signed this letter.

CAISO: Small Generator Interconnection Procedures (SGIP) Reform | August 4, 2010
This submission focuses on SGIP reform and the CAISO’s efforts to collapse the SGIP and Large Generator Interconnection Procedures (LGIP) into a unified process. The FIT Coalition opposes this effort because it will substantially increase interconnection timelines and costs for small generators. Additionally, we are concerned that SGIP reforms will also result in similar, negative changes to the Wholesale Distribution Access Tariffs (WDATs) by the investor-owned utilities.

CPUC: Long Term Procurement Proceeding (LTPP) | July 26, 2010
Reply comments focus on rebutting claims made by SCE and also supporting one of SCE’s claims with respect to the need for workshops.

CAISO: No Elimination of Small Generator Interconnection Procedures (SGIP) | July 17, 2010
The Clean Coalition’s letter to the CEO of the CAISO raised the voice of smaller developers and insisted that the Small Generator Interconnection Procedure (SGIP) not be eliminated without an adequate analysis and a proposal that accounted for the realities of smaller project development. This letter was signed by 80 parties from across the country and was also delivered to the Commissioners of the CPUC, CARB, CEC, and FERC.  This action led to the CAISO’s first efforts to reach out to the small project developer community.

CPUC: Long Term Procurement Proceeding (LTPP) | July 16, 2010
Reply comments focus on rebutting claims made by SCE and also supporting one of SCE’s claims with respect to the need for workshops.

CAISO: Small Generator Interconnection Procedures (SGIP) Reform | June 21, 2010
This submission focuses on SGIP reform and the CAISO’s efforts to collapse the SGIP and Large Generator Interconnection Procedures (LGIP) into a unified process.  The FIT Coalition opposes this effort because it will substantially increase interconnection timelines and costs for small generators.  Additionally, we are concerned that SGIP reforms will also result in similar, negative changes to the Wholesale Distribution Access Tariffs (WDATs) by the investor-owned utilities.

CPUC: Long Term Procurement Planning (LTPP) | June 3, 2010
This submission focuses on the Long Term Procurement Planning (LTPP) proceeding at the CPUC, and the purpose of the comments is to highlight the need for the utilities’ long-term procurement plans to include a heavy focus on WDG.

CAISO: Small Generator Interconnection Procedures (SGIP) Reform | April 26, 2010
This submission focuses on SGIP reform and the CAISO’s efforts to collapse the SGIP and Large Generator Interconnection Procedures (LGIP) into a unified process. The FIT Coalition opposes this effort because it will substantially increase interconnection timelines and costs for small generators. Additionally, we are concerned that SGIP reforms will also result in similar, negative changes to the Wholesale Distribution Access Tariffs (WDATs) by the investor-owned utilities.

CARB: Renewable Electricity Standard (RES) Draft | March 25, 2010
These comments show how the proposed RES portfolio mix will cost CA citizens significantly more than a high WDG portfolio.  An unbundled out-of-state REC for example costs $130 more than a REC generated by WDG solar PV.  These comments recommend adjustments to the penalty system to properly value WDG RECs.

CARB: Renewable Electricity Standard (RES) Technical Analysis | January 26, 2010
These comments recommended that in doing a Technical analysis of the potential renewable resources for the Renewable Electricity Standard (RES), CARB should strongly consider the high WDG scenario.  A High WDG scenario avoids transmission issues and long timelines and RES Compliance should encourage the high WDG path.

CARB: Renewable Electricity Standard (RES) Economic Analysis | January 26, 2010
These comments recommended that in doing an economic analysis of the Renewable Electricity Standard (RES), CARB should consider the significant economic benefits fo a high WDG scenario driven by a comprehensive FIT. A FIT would provide lower costs and rates while creating more ecnomic benefits to CA in terms of jobs.

2009

CARB: Renewable Electricity Standard (RES) Concept Outline | November 20, 2009
These comments described a set of design principles for the RES that would minimize risk and costs in achieving the 33%-by-2020 mandate.  The design that would best fit the top priority goals of the RES should focus on tapping the Wholesale Distributed Generation (WDG) market with a comprehensive Feed-In Tariff.

CPUC: Renewables Auction Mechanism (RAM) | November 10, 2009
These comments are a full response to the ALJ request for comments on the Energy Divisions’ Renewables Auction Mechanism.  Overall, the many flaws in the RAM are detailed and the recommendation is to instead a cost-based Feed-In Tariff. These comments also specify the need for the PUC to require utilities to pre-identify interconnection areas with low potential network upgrade costs.

CPUC: Renewables Auction Mechanism (RAM) | October 19, 2009
These comments are focused the PUC’s FIT Pricing and Structure Rulemaking proceeding.

CEC: Feed In Tariffs | June 11, 2009
These comments detail the four methods by which a comprehensive FIT would produce net savings for California ratepayers.

2008

CEC: Quantifying the Effect of Natural Gas Price Elasticity on the Cost of a Feed-In Tariff | December 6, 2008
This analysis provides specific calculations for how a Feed-in Tariff would affect the price of natural gas in California.  A FIT would replace demand for electricity generated by natural gas and this demand reduction would reduce the price of natural gas across the state. The German FIT experience has shown this “substitution effect” to be significant, saving the German citizens more money than the premium paid for renewable energy with a FIT.