Regulatory filings 2008 - 2024

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.

2024

CPUC: PG&E’s Motion to Revise 2025 and 2026 Energization Cost Caps — Direct Testimony on PG&E’s Motion to Revise 2025 and 2026 Energization Cost Caps | 9 December 2024
Clean Coalition testimony succintly details our concern that PG&E is requesting billions in extra funding to reduce the existing energizations backlog, but has no plan to hire and train new staff or prepare for a future with consistently increasing numbers of energization requests as the state electrifies. We argue that continuing to rely on high priced contractors is not sustainable and likely risks another backlog developing in the future, both of which are unacceptable outcomes for the ratepayers. Clean Coalition’s testimony urges the CPUC to reject PG&E’s motion until further detail is provided and PG&E explains why acceptance of the business-as-usual approach to staffing is sustainable and cost-effective in the long-term.

CPUC: Future of the Grid Study — Comments on Future of the Grid Study | 6 December 2024
These Joint Comments seek a forward looking framework that values and compensates distributed energy resources (DER) and critique a lack of discussion of essential benefits of DER such as resilience. We argue that the sole reliance on a natural monopoly in discussions on the future of the grid falls short of meeting the mark and discuss the importance of distribution-level markets, enabling resilience via Community Microgrids, the need for an open access distribution system, and restructuring to center around a bottom-up structure for resource planning.

CPUC: Community Microgrids Tariff — Reply Comments on Proposed Decision | 14 October 2024 
Clean Coalition’s reply comments support the adoption of CALSSA’s proposal to make permanent the removal of storage sizing limits, request that the Commission adopt GPI’s proposals on oversizing and developing a Community Microgrid pre-application report, support the need to implement binding study timelines for SCE rather than an “estimate”, concur with PearlX on the criticality of valuing resilience, and note that MRC is correct that the options for Rule 18/19 are insufficient to meet customer’s resilience needs. Overall, we disregard the Proposed Decision as insufficent to commercialize Community Microgrids and failing to meet the spirit and letter of SB 1339.

Department of Energy: DER Interconnection Roadmap — Comments on Draft DER Interconnection Roadmap | 10 October 2024 
Clean Coalition strongly supports the draft report and recommends a number of guidelines and specific actions that should be included in the final report. We address a number of hosting capacity related reforms that should be added based on flaws in the Interconnection Capacity Analysis (ICA) maps in California, propose an opt-in feature for the sharing of general interconnection data, propose streamlining interconnection for front-of-meter projects, offer the Clean Coalition’s Fixed Fee Utility Pays (FixUP) to lower costs for FOM projects under 1 MW, request the inclusion of a pre-application report as an important solution, propose binding timelines and delay penalties, suggest additional information on changing the cost-causer model, and provide information on flexible interconnections.

CPUC: Distribution Planning and ICA — Reply Comments on Proposed Decision | 8 October 2024 
Clean Coalition’s reply comments support IREC’s recommendation for a binding 18-month timeline for the utilities to address all known ICA issues following quarterly workshops, urge the CPUC to reject utility arguments about reducing ICA reporting and workshops, uplift GPI’s request that the Judge should provide information on how ICA issues will be considered in the Rule 21 interconnection proceeding, reinforce the value of VGIC’s proposal to create a Limited Load Profile in the ICA maps, and suggest the CPUC should clarify that a consultant will be responsible for conducting the Electrification Impacts Study Part 2.

CPUC: Community Microgrids Tariff — Opening Comments on Proposed Decision | 7 October 2024
Clean Coalition’s comments strongly oppose the Proposed Decision. We argue that adopting PG&E’s Community Microgrid Enablement Tariff (CMET) as a Community Microgrid tariff without evaluating a program that has resulted in zero deployed Community Microgrids in three years is foolish policymaking and note that the CMET is completely unworkable for disadvantaged communities (DACs). We lambast the CPUC for praising the Clean Coalition’s Resilient Energy Subscription (RES) proposal as “novel” and largely dismissing it by raising surface-level issues that have been addressed in our comments numerous times and grouping the RES with other dissimilar stakeholder proposals rather than addressing it directly. Lastly, we note that the CPUC hypocritcally justifies adopting the CMET by arguing that the status quo (existing programs) is sufficient to meet the needs of DACs rathr than arguing in favor of the CMET, while also claiming the stakeholder proposals do not go far enough to meet the needs of DACs. We argue that holding stakeholder proposals to a different standard than the utilities’ proposal is unreasonable and weaponizes the CPUC’s purported focus on supporting DACs to discredit participating stakeholders.

CPUC: Distribution Planning and ICA — Opening Comments on Proposed Decision | 4 October 2024
The Clean Coalition supports aspects of the Proposed Decision (PD), including Integration Capacity Analysis (ICA)-related changes where the CPUC listened to our recommendations. However, we argue that the PD fundamentally fails to consider party proposals surrounding the most important flaws of the ICA Data Portals (e.g., data inaccuracy, the rate of data refreshes by the utilities, inconsistent use of ICA data in the interconnection process, and untimely implementation of solutions to known problems) that prevent both the Generation and Load ICA maps from being used consistently by developers.

CPUC: Energization Timelines — Response to Motion to Amend Scoping Memo | 25 September 2024
Clean Coalition supports Enphase Energy’s Motion as an important strategy to increase flexibility on the distribution grid to ensure that long upgrade timelines do not inhibit progress toward achieving California’s climate and energy goals. Flexible energizations allow a request for new or increased service to be granted as quickly as possible even if the required capacity is not readily available on the distribution grid. A power control system can defer or prevent an otherwise needed upgrade. The CPUC is starting to pilot limited generation profiles; limited energizations is the next logical step and will increase pace of electrification.

FERC: San Diego Gas & Electric Filing Amending its Wholesale Distribution Access Tariff to Comply With FERC Order 2023 — Protest of SDG&E’s Compliance Filing Amending its Wholesale Distribution Access Tariff | 18 September 2024
Clean Coalition protests SDG&E’s filing as taking steps that do not comply with either the spirit or letter of Order 2023 and labels the proposal as disciminatory toward distributed energy resources (DERs) sized at or under 20 MW. We urge the FERC to reject SDG&E’s request to remove the Independent Study Process (ISP) from its Wholesale Distribution Access Tariff (WDAT) and shift entirely to a cluster study interconnection process. The ISP is the main study process used by DERs, and Order 2023 clearly states that a serial interconnection process should be retained for distribution-level projects. We note that neither PG&E nor SCE propose to remove the ISP, meaning that SDG&E’s request is not required to comply with Order 2023 or to harmonize with the changes proposed by the California Independent System Operator (CAISO). Given California’s need for new capacity and focus on wholesale distributed generation programs like Community Solar, we argue that removing the ISP would limit the effectiveness of state-programs if projects are instead required to be studied in upcomcing CAISO “superclusters” and note that SDG&E has very successfully used the ISP to interconnect almost 400 MW of energy storage and microgrids (by far the most utility-owned storage of any of the three investor-owned utilities).

CPUC: Energization Timelines — Reply Comments on Proposed Decision Adopting Target Energization Time Periods and Procedure for Customers to Report Energization Delays | 4 September 2024
Clean Coalition’s reply comments note widespread party support for adopting target time periods for projects requiring upstream grid upgrades rather than average timelines and observe that simply taking stock of existing timelines is insufficient to accelerate energizations in the manner required to achieve electrification in time to meet California’s legislative goals. We detail the importance of having an enforcement mechanism to ensure that the utilities comply with all targets adopted by the Commission, clarify that customer transformer upgrade should not be included in the category of targets for projects triggering upstream capacity upgrades, and request that the Commission clearly underscore in the Proposed Decision that the target time periods adopted are interim and will likely be amended/shortened annually.

CPUC: Energization Timelines — Opening Comments on Proposed Decision Adopting Target Energization Time Periods and Procedure for Customers to Report Energization Delays | 29 August 2024
Clean Coalition’s opening comments support the steps taken in the Proposed Decision (PD), though we argue that adopting timelines rather than target time periods for projects requiring upstream grid upgrades does not comply with Senate Bill 410 and Assembly Bill 50. We urge the Commission to resolve conflicting language in the PD by reducing the maximum target time period for a Main Panel Upgrade from 60 days to 45 days. Lastly we argue that the Commission must take stock of the utilities’ staff to ensure that an inadequate workforce is not leading to energization delays and suggest that SCE’s proposal for a “partial submission” process for large load projects be adopted for all three utillities.

CPUC: Renewable Market Adjusting Tariff (ReMAT) — Protest of SCE Advice Letter 5341-E | 12 August 2024
Clean Coalition’s protest of SCE’s Advice Letter (AL) 5341-E urges to the CPUC to reject SCE’s request to shift ReMAT Time of Delivery (TOD) factors to one across all hours. We argue that such a move would eliminate any incentive to deploy paired energy storage and dis-incentivizes operating a paired solar+storage system to align with grid conditions. Clean Coalition also notes that the new Community Solar program (the CREP) relies on ReMAT for base compensation; lowering compensation for paired storage further reduces the likelihood that paired storage projects will be deployed or that the CREP will have a chance of being successful and goes against past CPUC policy signals about the need for paired storage.

CPUC: Community Solar — Reply Comments on Administrative Law Judge Ruling Directing Responses on Implementation of Decision 24-05-065 | 29 July 2024
Clean Coalition reply comments urge the CPUC to properly compensate the additional value provided by paired energy storage, both time-shifting energy to peak periods and dispatchable capacity. We suggest that the ReMAT Time of Delivery (TOD) factors be updated to nonzero to incentivize storage deployments capable of exporting based on grid conditions, raise the issue of the CEC load modifier status, and note that the CAISO Distributed Generation Deliverability (DGD) allocation may be a more efficient pathway to allow Community Solar resources to be awarded deliverability than going through the 3+ year normal CAISO Cluster Study process. Lastly, we advocate that receiving incentives should not result in a lower PPA price for a project and that CCAs should be able to provide funds dedicated to local energy programs to subsidize Community Solar projects and/or increase low-income subscriber benefits.

CPUC: Avoided Cost Calculator — Opening Comments on Proposed Decision Adopting 2024 Changes to the Avoided Cost Calculator | 24 July 2024
Clean Coalition’s reply comments urge the Commission to reject an argument by the Joint IOUs to use the same inputs as 2022 for the avoided transmission value, urge the final Decision to direct consideration of a resilience adder in 2026, and support SEIA’s proposal to include $2.5 billion in transmission costs in the integrated calculation.

CPUC: Safety, Reliability, and Resiliency Standards — Reply Comments on Order Instituting Rulemaking | 23 July 2024
Clean Coalition’s reply comments urge the Commission to add resilience definitions and standards as a unique subject in the scope of the proceeding, request an emphasis on standards for distribution infrastructure, and note the importance of considering real impacts of all outages (scope, scale, and consequences), including for PG&E”s fast trip outages.

CPUC: Smarter Inverter Operationalization Working Group Reports — Reply Comments on Smart Inverter Operationalization Working Groups | 22 July 2024
Clean Coalition reply comments support the need to organize around two overarching issues: DER interconnection and grid services, rather than individual use cases. We urge the prioritization of ICA map improvements (to enable accurate and actionable data) given the criticality of siting and interconnection to flexible agreements, request the development of standard terminology for use across all CPUC proceedings, and emphasize the importance of transparent & accurate data sharing from the IOUs to CCAs.

CPUC: Transportation Electrification — Reply Comments on Ruling Initiating Track 1 and Inviting Comment | 18 July 2024
Clean Coalition reply comments urge the CPUC to reject IOU claims that Transportation Electrification funding should be cancelled and reallocated for infrastructure investments, notes that the proceeding record does not support pausing/cancelling funding, and provides reasons why continuing to fund transportation electrification is critical to the state achieving its ambitious climate and energy goals.

CPUC: Avoided Cost Calculator — Opening Comments on Proposed Decision Adopting 2024 Changes to the Avoided Cost Calculator | 16 July 2024
Clean Coalition comments support including the full avoided transmission value (based on the IOU’s entire transmission portfolio) in the 2024 ACC, requisition inclusion of a preliminary schedule for the upcoming transmission & distribution study to ensure that it happens in time for the 2026 ACC update, request that the Decision note that the updated avoided transmission values will likely be too low, and clearly state in the Decision that non-energy benefits are not currently considered but will be in time for the 2026 update.

CPUC: Community Solar — Opening Comments on Administrative Law Judge Ruling Directing Responses on Implementation of Decision 24-05-065 | 10 July 2024
Clean Coalition opening comments note that the base PURPA compensation for the new Community Solar program adopted by the CPUC will not be sufficient to incentivize Community Solar projects and urges the strategic dispersal of non-ratepayer funds to cover the compensation gap. We advocate for an allocation process that increases process certainty and incentivizes developers to shoulder the risk associated with deploying a Community Solar project. We propose an up-front lump sum payment, an adder for energy storage (which is currently voluntary and uncompensated), a built environment adder (including a carport/canopy solar adder and a requirement to install EV chargers), and a brownfield adder. Together, these adders incentivize project deployments in ideal locations and ensure that each project will create the maximum value possible for the ratepayers and the grid.

CPUC: Safety, Reliability, and Resiliency Standards — Opening Comments on Order Instituting Rulemaking | 8 July 2024
Clean Coalition’s opening comments advocate for a unique set of metrics that consider resilience impacts. We argue that separately addressing resilience from reliability is necessary since the two are different (though related) and creating unique metrics will better inform resilience-related investment priorities and validate compensation for resilience value creation. We address the need to modernize general orders related to safety to reflect the digital age and the growth in service territory sizes of the investor-owned utilities (IOUs), as well as the prevalence of planned outages such as public safety power shutoffs (PSPS) and PG&E’s Fast Trip outages. We conclude with the suggestion that increasing transparency by requiring the IOUs to have a central location with information on total transmission & distribution spending without going through the General Rate Case and Wildfire Mitigation Plan processes will benefit both the CPUC’s oversight ability and increase opportunities for interested stakeholders to participate in CPUC proceedings.

CPUC: Transportation Electrification — Ruling Initiating Track 1 and Inviting Comment | 2 July 2024
Clean Coalition’s comments strongly oppose pausing transportation electrification funding. We note that an up-front rebate, education & outreach, and pilots targeted at low-income Californians are critical for enabling equal access to electric vehicles and charging infrastructure in disadvantaged communities. Our comments argue that this funding is necessary now to help overcome historical inequities and set the stage for grid upgrades, DER deployments, and community-scale resilience and suggest that the CPUC consider transmission, wildfire spending, and cost overages related to Diablo Canyon as places to cut ratepayer costs rather than critical transportation electrification funding.

CPUC: General Order 131-D (Expedited Transmission Planning) — Comments on Phase II Staff Proposal | 1 July 2024
The Clean Coalition supports expediting infrastructure planning as long as the projects are required policy-related transmission projects approved by the CAISO and do not have a significant impact on either the environment or electric rates. We reiterate our desire for the CPUC to consider lifecycle costs before issuing a permit to proposed transmission projects, since O&M costs can be close to five times the cost (in real dollars) of the initial capital cost of a project. Finally, we strongly oppose the CPUC adopting a rebuttal presumption that the CAISO has sufficiently considered DER and non-wires alternatives for approved transmission projects. Clean Coalition argues that the CPUC has its own constitutionally-mandated responsibilities to consider other factors including the full range of benefits from DER, such as resilience, societal impacts, potential monetary benefits, and reduced GHG emissions.

CPUC: Energization Timelines — Reply Comments on ALJ Ruling Directing Responses to Questions on Energization Timelines | 28 June 2024
Clean Coalition reply comments identify inaccurate Load Integration Capacity Analysis (ICA) maps as a key barrier to swift energizations. We request increased structure around the process for main panel upgrades, a direct utility contact for each energization application, the development of a web portal for complaints/feedback, and suggest that improving the preliminary design process will make the energization process far more efficient. We also reiterate comments made in the High DER proceeding that proactive distribution planning, including increasing the acquisition of infrastructure components such as transformers, will greatly improve energization timelines across all three utilities.

CPUC: Integration Capacity Analysis and Distribution Planning — Reply Comments on Staff Proposal | 18 June 2024
Clean Coalition’s reply comments focus on the need to improve the Integration Capacity Analysis (ICA) maps to the point where they are accurate and actionable for siting/interconnection purposes, as envisioned when initially adopted by the CPUC. We support a majority of parties in calling for transparency and accountability in the form of a new working group, a centralized email for all ICA issues/queries, requiring the utilities to increase staff/computing power, and mandating that SCE records & addresses all known ICA issues within a year. We strongly support the work IREC has done to identify major ICA flaws and note that there has been a lack of stakeholder engagement, CPUC oversight, and in some cases (namely by SCE), major system flaws have been largely dismissed without any root cause analysis. Finally, we support GPI’s request for clarification on timelines for the energization and interconnection proceedings and support an opt-out process for the 15/15 rule.

CPUC: Adopting a Societal Cost Test — Opening Comments on Proposed Decision Adopting a Societal Cost Test | 13 June 2024
The Clean Coalition’s individual comments support the adoption of a Societal Cost Test (SCT) for DER cost-effectiveness purposes, though we urge the CPUC to incorporate the SCT as the primary test rather than an informational qualitative test. We then turn to the subject of resilience, arguing that the SCT is the proper way to value societal benefits from energy resilience, noting that there are two unique societal benefits associated with resilience. First, resilience at critical facilities that provide emergency services benefits the local community and the broader region, for whom emergency planning and consistent services is quite valuable and enables the ability to shelter in place. Second, all DER deployments set the stage for community-scale resilience, namely Community Microgrid deployments. We note, from a procedural standpoint, that the CPUC has refused to address the subject of resilience in a number of other forums, making this proceeding the appropriate place to value societal resilience, and showcase two programmatic examples, the Microgrid Incentive Program and Liberty Utility’s resilience program, where valuing resilience is necessary to make proper decisions about success/long-term viability.

CPUC: Adopting a Societal Cost Test — Opening Comments on Proposed Decision Adopting a Societal Cost Test | 13 June 2024
These Joint Comments support the adoption of a Societal Cost Test (SCT), with a number of modifications. First, we request that the be used across all DER proceedings including to inform resource procurement for the state energy portfolio and request that the CPUC remove language that concludes that relying on societal costs will inherently lead to rate increases. We propose that the CPUC should use the updated Social Cost of Carbon released by the federal government, increase the local air quality adder, and incorporate non-energy benefits once adopted by the Energy Commission. The comments also note that federal subsidies do not accrue to California without investments in DER and therefore, federal tax credits should be valued as a benefit rather than zeroed out as a tax transfer.

CPUC: High DER Staff Proposal on Distribution Planning and Integration Capacity Analysis — Opening Comments on Staff Proposal | 29 May 2024
The Clean Coalition supports many options offered in the Staff Proposal, noting that distribution planning needs to be streamlined in a way that includes a longer-term planning horizon and provides an appropriate number of opportunities for distributed generation to defer traditional infrastructure upgrades. We support proposals to improve the Integration Capacity Analysis (ICA), but focus our advocacy on the need to improve the overall quality of the tools via data and results validation before addressing minute cosmetic improvements to the maps. We lay out ways that the Load ICA is far less accurate than the Generation ICA and explain that of the three utilities, SCE is lagging far behind PG&E and SDG&E in ICA usefulness and improvements.

CEC: Non-Energy Benefits in the SB 100 Report and Newly Opened Proceeding on Social Costs — Opening Comments | 21 May 2024
Joint Coalition comments advocate for the inclusion of Non-Energy Benefits and Social Costs in the decision making framework. The comments explain how these factors can be included in the capacity analysis models to help inform the regulatory agencies on the portfolio (and accompanying infrastructure) that produces the greatest net benefits for the ratepayers, rather than solely considering the least cost of generation. We argue that incorporating these metrics is integral to actively considering the needs of disadvantaged communities and aligns with goals adopted by the CEC and CPUC.

CPUC: Enphase Energy Motion to Amend Scoping Memo to Address Flexible Connection Agreements — Response to Motion to Amend Scoping Memo | 21 May 2024
The Clean Coalition’s response strongly supports the Motion by Enphase Energy. We note that infrastructure upgrades have a huge impact on DER siting. A project that triggers an upgrade will often be abandoned due to the high cost or the long lead time before an upgrade can be completed. As a result, flexible connections are an important solution to utulize the existing grid in the most effective way possible. Operating DER within the limits of the existing hosting capacity benefits both the DER owner and the utility. Standard options, not just pilots, are needed to enable a future with a high penetration of DER.

CPUC: Microgrids — Reply Comments on Party Responses to ALJ Ruling Requesting Comment on Alignment with the CPUC’s Environmental and Social Justice (ESJ) Action Plan 2.0 | 17 May 2024
Clean Coalition reply comments focus on the fact that our Resilient Energy Subscription (RES) proposal will not create a cost shift, as inferred by the Joint IOUs. We underscore how resilience for critical community facilities benefits the broader community and that funding resilience is in line with the goals in the CPUC’s ESJ Action Plan 2.0. The RES provides a framework for investing in ESJ communities in a way that benefits the entire community, from resilience at critical community facilities to the ability to scale up the footprint of a Community Microgrid deployment over time to serve a greater number of ratepayers.

CPUC: Microgrids — Comments on Party Responses to ALJ Ruling Requesting Comment on Alignment with the CPUC’s Environmental and Social Justice (ESJ) Action Plan 2.0 | 3 May 2024
Clean Coalition comments highlight the alignment between our Resilient Energy Subscription (RES) proposal and the goals in the CPUC’s Environmental and Social Justice (ESJ) Action Plan 2.0. The RES is a fee-based market mechanism that finances the deployment of scalable Community Microgrids and is complementary with other base tariffs. We explain that in the context of the Microgrids proceeding alignment with the ESJ Action Plan refers to the creation of a tariff that will lead to successful Community Microgrid deployments in ESJ communities and juxtapose the lack of success thus far from PG&E’s Community Microgrid Enablement Tariff (CMET). Lastly, we clarify that the RES subscriptions will recover the of all microgrid-related startup costs (capex, opex, and a rate of return) and ask the IOUs detailed questions about how they use the phrase the “cost-shift”.

CPUC: Microgrids — ALJ Ruling Requesting Comment on Alignment with the CPUC’s Environmental and Social Justice (ESJ) Action Plan 2.0 | 19 April 2024
The Clean Coalition’s comments contextualize alignment with the ESJ Action Plan in this proceeding as meaning that the Commission should adopt a viable tariff that will result in Community Microgrid deployments in ESJ communities in a timely manner. We explain that our Resilient Energy Subscription (RES) proposal – a $/kWh subscription fee-based market mechanism – aligns with Goals 1, 2, 3, 4, 7, and 9 of the ESJ Action Plan 2.0. Promoting renewables-driven Community Microgrids will result in an unparalleled trifecta of economic, environmental, and resilience benefits in the ESJ communities where they are deployed. The RES enables such deployments to be scalable, serving additional parts of the Community over time, and financeable, with cost-effective resilience for critical loads at Critical Facilities and subscribers.

CEC: 2024 Integrated Energy Policy Report (IEPR) — Comments on Scope for 2024 IEPR | 5 April 2024
The Clean Coalition urges the Energy Commission to ask the fundamental question, “what steps are needed to get the state back on track to achieve its climate and energy goals?” as an overarching theme for the 2024 IEPR. We note the lack of development of community-scale renewables, point out the problem of long timelines for capacity projects to complete both a front-of-meter interconnection & the deliverability study process, underscore that the state can save the ratepayers billions by smartly siting distributed generation in addition to utility-scale resources, and identify the Transmission Access Charges (TAC) market distortion as a critical issue that artificially depresses the value of distributed generation and increases the difficult of reaching state procurement targets.

CPUC: Community Solar — Reply Comments on Proposed Decision | 1 April 2024
The Clean Coalition emphasizes consensus amongst parties that the CPUC’s proposed new Community Renewable Energy Program (CREP) will not work, diving into a litany of issues from insufficient compensation to flaws in the existing PURPA Feed-In-Tariffs to a lack of consideration of integral programmatic details to a lack of compliance with the CEC’s Title 24 Building Standards. We note vast support for the Net Value Billing Tariff (NVBT) and promote legal arguments that justify the NVBT as a retail program and not a wholesale transaction. These comments pave the way for the CPUC to reject the CREP and adopt the NVBT.

CPUC: Community Solar — Opening Comments on Proposed Decision | 25 March 2024
The Clean Coalition criticizes the Commission for rejecting the Net Value Billing Tariff and instead selecting two failed PURPA Feed-In-Tariffs (ReMAT and the Standard Offer contract (SOC)) as base compensation for a new Community Solar program. Both ReMAT and the SOC are priced far too low to interest developers, have program intricacies that are incompatible with Community Solar, and the Commission provides no detail about how a new Community Solar program would be counted toward capacity targets for the existing programs. We argue that the PD fails to properly value the full benefits from Community Solar, especially Infill Solar, and urge the Commission to use the Clean Coalition’s original Feed-In-Tariff design based on the Feed-In-Tariff we designed for the City of San Diego and LADWP’s FIT+ program. Lastly, we lament that requiring Community Solar projects to use a front-of-meter interconnection with the utility’s WDAT processes adds years to the interconnection process and at least $0.02-$0.04/kWh in costs which will prevent an already dormant Community Solar market from maturing.

CPUC: Virtual Net Energy Metering — Protest of PG&E Advice Letter 7175-E | 5 March 2024
The Clean Coalition protests PG&E’s implementation of the new Virtual Net Energy Metering (VNEM) tariff due to the lack of information or technical specifications on how a VNEM system can be used for resilience during a grid outage. The lack of clarity/additional information in the two years since language about resilience was initially added to the VNEM 2.0 tariff represents a lack of effort on PG&E’s part to create a standard process, effectively putting resilience out of reach for multi-unit housing and other multi-meter facilities. We promote master metering as a crucial solution that will solve the lack of options for resilience.

CPUC: Virtual Net Energy Metering — Protest of SCE Advice Letter 5203-E | 4 March 2024
The Clean Coalition protests SCE’s implementation of the new Virtual Net Energy Metering (VNEM) tariff due to the lack of information or technical specifications on how a VNEM system can be used for resilience during a grid outage. The lack of clarity/additional information in the two years since language about resilience was initially added to the VNEM 2.0 tariff represents a lack of effort on SCE’s part to create a standard process, effectively putting resilience out of reach for multi-unit housing and other multi-meter facilities. We promote master metering as a crucial solution that will solve the lack of options for resilience.

CPUC: 2024 Update to the Avoided Cost Calculator — Opening Brief | 21 February 2024
The Clean Coalition’s Opening Brief underscores the need to fully value avoided transmission in the ACC for proper compensation of distributed energy resources (DER). We acknowledge that a detailed study will be conducted in time for the 2026 ACC and urge the CPUC to use an interim value for SCE and SDG&E based on the methodology adopted for PG&E in the 2022 ACC update, Lastly, we support SEIA’s proposal to incorporate the costs of policy-related transmission projects (currently valued at $0) in the existing modeling for the state resource portfolio for more accurate ACC outputs.

CPUC: Virtual Net Energy Metering — Protest of SDG&E Advice Letter 4383-E | 19 February 2024
The Clean Coalition protests SDG&E’s implementation of the new Virtual Net Energy Metering (VNEM) tariff due to the lack of information or technical specifications on how a VNEM system can be used for resilience during a grid outage. The lack of clarity/additional information in the two years since language about resilience was initially added to the VNEM 2.0 tariff represents a lack of effort on SDG&E’s part to create a standard process, effectively putting resilience out of reach for multi-unit housing and other multi-meter facilities. We promote master metering as a crucial solution that will solve the lack of options for resilience.

CPUC: Income Graduated Fixed Charges — Reply Comments on ALJ Ruling on Implementation Budget and Timing Issues (Track A) | 12 February 2024
The Clean Coalition’s reply comments underscore the fact that the record of the proceeding does not support a Fixed Charge as being the best solution to increase the pace of electrification, nor even a solution that is beneficial. We protest the Joint IOU’s arguments about high charging costs limiting EV adoption to wealthier income as a red herring that ignores the main factor in switching: a high up-front capital cost priced beyond what many LMI customers can handle. We advocate for transitioning customers to electrification rates, reforming the volumetric rate with a lower winter off-peak rate, and reiterate the significant consequences from proposals for a high Fixed Charge.

CPUC: Integrated Energy Policy Report (IEPR) — Comments on Proposed Final 2023 IEPR | 9 February 2024
The Clean Coalition appreciates the detailed recommendations on interconnection reform in the proposed 2023 IEPR, including Clean Coalition’s suggestions on data transparency, improved ICA maps, and automation. We detail a number of other solution that should be included in the recommendations section, needed to greatly improve the viability of the interconnection process, particularly in the wholesale distributed generation market segment (that interconnects via the WDAT).

CPUC: Transportation Electrification — Reply Comments on Order Instituting Rulemaking | 5 February 2024
The Clean Coalition’s reply comments on the Order Instituting Rulemaking (OIR) support the Commission’s decision to create a single holistic proceeding that addresses the big picture when it comes to transportation electrification. We argue that the proceeding should consider a number of issues, including resilience & microgrids, lowering ratepayer costs through managed charging, the need for greater transparency and granular data related to grid planning, shifting consumer behaviors, EV uptake, and equity issues (such as most low-income residents working 9-5 jobs, making them unable to charge during ideal grid conditions, and low existing DER/EV deployment rates in disadvantaged communities).

CEC: Non-Energy Benefits — Petition for Rulemaking | 5 February 2024
The Clean Coalition joins the Center for Biological Diversity and other petitioners in requesting that the Energy Commission include non-energy benefits and social costs into the resource planning framework. Currently the Energy Commission acknowledges that these externalities have value and should be considered in the decision-making process, but do not have any any methodology in place, nor is there a plan to practically value the non-energy benefits from DER. If approved, this petition will fundamentally change the way that the state plans for new grid infrastructure and designs the electric resource portfolio.

CPUC: General Order 131-D (Expedited Transmission Planning) — Comments on Phase II Issues | 5 February 2024
The Clean Coalition’s joint comments with the Center for Biological Diversity and the Protect our Communities Foundation advocate that the CPUC should take the role of the lead agency in studying environmental effects from proposed transmission projects. We argue that the Permit-to-Construct (PTC) process should be differentiated based on projects constituting substantial impacts and non-substantial impacts, ensuring that the PTC process does not become a tool to avoid CEQA. We urge the Commission to include a greater analysis of DER alternatives, to consider lifetime project costs, and to reject any IOU proposals from the Phase I proposed settlement agreement.

CPUC: Microgrids — Reply Comments Responding to Opening Comments on Optional Community Microgrid Tariff Submissions | 26 January 2024
The Clean Coalition’s reply comments highlight the consensus support amongst parties for our Resilient Energy Subscription (RES) proposal. We discuss our support for allowing Community Microgrids to operate as one controllable entity (during blue sky operations), urge the Commission to value the full range of benefits created by Community Microgrids, note the need for front-of-meter interconnection reform, suggest that Community Microgrid resources should be studied in tandem, and support capacity compensation mechanisms proposed by other parties.

CPUC: Income Graduated Fixed Charges — Comments On ALJ Ruling on Implementation and Timing Issues | 24 January 2024
The Clean Coalition’s comments explain that high Fixed Charges do not promote electrification and instead recommend volumetric rate reform, to promote lower off-peak rates that best match the demand profile under electrification scenarios. We argue that adopting a high Fixed Charge is like bailing water on a ship with a hole in it and advocate that the Commission should prioritize rate reform along with curbing the underlying cost drivers of electric rates, namely spending on transmission infrastructure.

CPUC: Microgrids — Comments in Response to Optional Community Microgrid Tariff Submissions | 12 January 2024
The Clean Coalition’s response to Community Microgrid proposals supports the consensus around the need for more bankable value streams for Community Microgrids, including avoiding Transmission Access Charges (TAC), the vale of resilience, distribution deferral, non-energy benefits, wildfire mitigation, facilitating electrification, etc… We highlight GPI’s comments about the need to commercialize Community Microgrids through standard and replicable models rather than unique projects and non-replicable configurations and reiterate support for Sunnova’s Master Metered Housing Community Microgrid proposal.

2023

CPUC: Microgrids — Optional Community Microgrid Tariff Submission | 15 December 2023
The Clean Coalition’s submission details the Resilient Energy Subscription (RES), a revolutionary fee-based market mechanism that enables the establishment, enhancement, and expansion of Community Microgrids designed around Critical-Community Facilities (CCFs). Our comments explain how to determine an appropriate level of resilience for individual facilities by tiering loads and underscore that the same can be done for an entire distribution grid area, with socialized costs for critical loads at CCFs. We demonstrate how the RES would be applied to different sized Community Microgrids using examples from the Goleta Load Pocket and highlight the multifaceted benefits of Community Microgrids (which will increase over time as we are more reliant on electricity due to electrification/decarbonization).

CPUC: Community Solar — Reply Comments on ALJ Ruling Setting Record Aside and Taking Comments | 7 December 2023
The Clean Coalition’s reply comments note that a successful Community Solar market is imperative to meet the state’s clean energy/reliability goals, which makes a program that properly values essential. We request a full valuation of the benefits of infill solar and inclusion of an option for deployments of unbundled storage. We also reject SCE’s critiques of the Net Value Billing Tariff (NVBT) and SCE’s proposal for a PURPA-based program, advocate for locational benefits, note that proposed program guardrails (program cap, sunset date, and siting limitations) are unnecessary at the moment, and advocate for streamlined interconnection of NVBT projects using Rule 21.

CPUC: DER Deferral (DIDF) — Advice Letters Requesting the Commission Allow No Further 2023 DIDF RFO Solicitations | 5 December 2023
The Clean Coalition’s protest urges the Commission to reject the IOU’s Advice Letters due to the millions of dollars’ in ratepayer savings from successful deployments of DER deferral projects. We note that SDG&E’s arguments for removal of resiliency as a DER deferral option entirely are concerning, given the opportunity for third parties to procure projects which have already approved by the Commission (meaning 100% certainty that a successful bid will lead to a constructed project) and out of scope for this proceeding. We note that SCE’s request to not solicit the deferral of a transformer ignores past success from similar deployments and global supply chain constrains for transformers and suggest that PG&E should solicit two substation projects with overall “positive scores”.

CPUC: Community Solar — Opening Comments on ALJ Ruling Setting Record Aside and Taking Comments | 27 November 2023
The Clean Coalition’s comments advocate for the adoption of unbundled (virtual) storage as the best way to increase the value to the ratepayers and result in direct grid benefits. We underscore that deployments under the Net Value Billing Tariff (NVBT) should reduce the local Load Serving Entity’s (LSEs) requirement for Local Resource Adequacy (RA) via a reduction in the CEC’s peak load calculation. We also note that the proceeding record does not support adding a sunset date or program cap and urge the Commission to allow for usage of Rule 21 for interconnection, rather than the time-intensive/costly WDAT (and deliverability) study process.

CPUC: Avoided Cost Calculator — Rebuttal Testimony on the 2024 ACC Staff Proposal | 20 November 2023
The Clean Coalition’s Rebuttal Testimony reiterates the need for a fully updated avoided transmission methodology, given the fact that the Commission is now using the ACC directly as a mechanism to determine compensation for DER programs. We argue that putting off the update to 2026 will actively result in an improper value stacks with less-than-appropriate compensation for customers enrolled in NEM, VNEM, Community Solar, and Energy Efficiency programs.

CEC: SB 100 Report — Comments on SB 100 Workshop on Modeling Inputs | 14 November 2023
The Clean Coalition’s comments support the Energy Commission’s focus on accurately modeling a reasonable target for distributed front-of-meter (FOM) capacity to help the state hit clean energy targets. We urge the Energy Commission to analyze the value of the Vibrant Clean Energy study, which concludes that ratepayers will save $120 billion with smartly sited DER (along with utility-scale deployments) and suggest that 12.5 GW is an ideal target. Through analysis of CAISO data from the near-outage situation on 6 September 2022, our comments demonstrate that 12.5 GW of local solar would have been more than enough to reduce peak transmission usage and ensure that an outage did not occur. Finally, we underscore that the value of DER deployed in load pockets or managed by a Distribution System Operator will increase over time, adding another incentive to include a high target for FOM DER in the SB 100 Report.

CPUC: Microgrids — Reply Comments on the IOU’s Community Microgrid Enablement Tariff (CMET) | 13 November 2023
The Clean Coalition’s reply comments underscore the need for overall certainty (with regards to process/timelines, design requirements, and expected costs) in a tariff intended to enable Community Microgrid deployments. We note that there is a complete lack of data from PG&E about the Community Microgrid Enablement Tariff (CMET) and correlate the lack of success with the need to make fundamental changes to fully commercialize microgrids. We advocate for a unified interconnection process for Community Microgrid resources, argue that islanding for economic reasons will benefit the ratepayers (through GridOptimal performance), underscore the fundamental need for a fee (like the Resilient Energy Subscription, RES) to recover costs, and discuss the benefits of residential master metering at multi-unit housing facilities.

CPUC: Income Graduated Fixed Charges — Reply Briefs | 3 November 2023
The Clean Coalition’s reply brief explains that our streamlined proposal meets the statutory requirements of AB 205, avoiding the creation of a massive subsidy from small residences to large homes, and urges the CPUC to adopt our three-tiered proposal (with tiers for CARE, FERA, & everyone else) as well as fixed cost categories. We then note that proponents of high Fixed Charges have been unable to mitigate the negative implications on energy efficiency, load shaping, and conservation; just as important, we explain that the record does not reflect that a High Fixed Charge is necessary to enable, or is beneficial for, electrification.

CPUC: General Order 131-D (Expedited Transmission Planning) — Response to the Joint Motion to Adopt the Settlement Agreement | 30 October 2023
The Center for Biological Diversity and the Clean Coalition’s response firmly opposes the IOU’s proposed settlement as illogically trying to change the Scoping Memo, not reflecting the proceeding record, and attempting to include solutions to issues from Phase 2. We urge the CPUC to focus on implementing SB 529 in Phase 1 as was scoped into the proceeding, rather than adopting a premature settlement agreement.

CPUC: Avoided Cost Calculator — Opening Testimony on the 2024 ACC Staff Proposal | 30 October 2023
The Clean Coalition’s testimony advocates that the CPUC should reject any ACC update that does not include an updated avoided transmission methodology, given the mandate requiring a methodology change in the decision adopting the 2022 ACC. In addition to our concern about the lack of initiative by Energy Division staff in making the required change to the specified avoided transmission value, we request the creation of an unspecified avoided transmission value, and explain why avoided Transmission Access Charges should be included (to value reduced congestion and line losses plus improved economic outcomes on the transmission system).

CPUC: Microgrids — Opening Comments on the IOU’s Community Microgrid Enablement Tariff (CMET) | 27 October 2023
The Clean Coalition’s comments underscore that a successful Community Microgrid tariff needs better certainty (process/timeline certainty, design certainty, and cost certainty) than what is contained in the Community Microgrid Enablement Tariff (CMET) submitted by the IOUs. We detail our Resilient Energy Subscription (RES) fee-based proposal to establish, enhance, and expand Community Microgrids around Critical Community Facilities and explain why this proposal will lead to the widespread deployment of Community Microgrids.

CPUC: Income Graduated Fixed Charges — Opening Briefs | 6 October 2023
The Clean Coalition’s Opening Brief underscores why our proposal meets the requirements of AB 205 and is the most practical to implement. We detail how high Fixed Charges upend incentives for conservation, energy efficiency, electrification, and on-site generation and advocate for volumetric rates with a higher on-peak off-peak price differential. We conclude by urging the Commission adopt our proposal and fixed cost categories, rather than authorized a second version Fixed Charge.

CPUC: General Order 131-D (Expedited Transmission Planning) — Reply to Motion of the Joint IOUs | 4 October 2023
The Joint Parties oppose the Joint IOU’s Motion to for Expedited Treatment and to Amend the Scoping Memo. We explain how the Joint IOUs are attempting to settle issues from Track 1 and 2 of the proceeding with relying on the existing proceeding record or the difficulty for other parties to fully analyze and comment in time.

CPUC: Distribution Planning Process  — Reply Comments in Response to IOU’s Response to Amended Scoping Memo Appendix A | 28 September 2023
The Clean Coalition’s reply comments focus on the value of DER deferral and urge the Commission to prioritize the evaluations of DER solutions in the Distribution Planning Process. We note that two DER deferral projects in SCE’s service territory resulted in $7.56 million in ratepayer savings and that distributed projects will save both money and time.

CEC: SB 100 Kickoff Workshop  — Comments on SB 100 Kickoff Workshop | 15 September 2023
We urge the Energy Commission to forecast a scenario with a high penetration of DER and underscore the multifaceted benefits from DER including economic, environmental, and resilience benefits. We also discuss how DER fit in with the state’s broader vision for the future and are vital to achieving clean energy & electrification goals.

CPUC: Upcoming Proposed Decision  — Ex parte meeting with President Reynolds’ Office | 6 September 2023
This slide deck advocates that President Reynolds should write a Proposed Decision that compensates the full value of Infill Solar. We discuss how this additional value from Infill Solar (as opposed to remote ground solar projects) should be compensated through avoiding Transmission Access Charges and the Power Charge Indifference Adjustment. We discuss the significant siting potential of Infill Solar, advocate for virtual (unbundled) storage, using the ACC rather than LCBF, and the insufficiency of the existing programs.

CPUC: Proposed Decision Address Remaining Issues  — Reply Comments on Proposed Decision | 28 August 2023
The Clean Coalition’s reply comments note the difficulty of getting information on the virtual net energy metering program (VNEM) from customer-facing divisions of the IOUs and note that this PD will make things more confusing for participating ratepayers. We request an Alternative Proposed Decision that includes property-level netting since energy flows to nearby loads and pathways to deploy storage and resilience solutions. Finally, we point out that this PD will adversely impact renters and low-income Californians, which is opposite to what the Commission is attempting to do.

CPUC: ALJ Ruling on Implementation Pathways for Income Graduated Fixed Charges  — Reply Comments on ALJ Ruling | 21 August 2023
The Clean Coalition’s reply comments underscore the need to consider impacts on electrification, conservation, efficiency, and self-generation from implementing a fixed charge. We urge the Commission to adopt our low fixed charge, reject any high fixed charge proposal, and move forward with a greater time-varying TOU rate. Finally we explain why the Joint IOUs proposal is actually three different proposals that should not be adopted and highlight that NRDC/TURN including the PCIA in their proposal is enough to remove it from consideration.

CPUC: ALJ Ruling on Scope of Work for Consultant and Data Working Group  — Opening Comments on ALJ Ruling | 11 August 2023
The Clean Coalition’s opening comments request the inclusion of resilience and interconnection-related data issues in the scope of the data working group. We also advocate for a discussion of non-energy benefits, since this proceeding is the appropriate forum to do so.

CPUC: ALJ Ruling Setting Aside the Record and Questions on Cost-Effectiveness  — Reply Comments on ALJ Ruling | 10 August 2023
The Clean Coalition’s reply comments underscore the unique value that infill projects create beyond what is valued in the Avoided Cost Calculator (ACC) and make the case that avoiding Transmission Access Charges (TAC) and the Power Charge Indifference Adjustment (PCIA) is the appropriate way to compensate the value creation. We challenge the IOUs by proving why the ACC is the appropriate tool to use for valuing distributed generation and advocate for the Commission to allow unbundled storage in the program to maximize the value from economies of scale.

CPUC: Electrification Impacts Study Part 1  — Reply Comments | 7 August 2023
The Clean Coalition’s reply comments detail the multi-faceted value that microgrids can create in the grid planning process (using the example of a microgrid islanding a fleet of EV chargers), highlight the need to increase the timeframe considered in the distribution planning process and increase, and affirm the importance of proper/accurate assumptions & inputs prior to the start of Part 2 of the Study.

CPUC: Public Participation Hearings about Income Graduated Fixed Charges  — Joint Reply to the Joint Utilities’ Response on the Joint Motion for Public Participation Hearings | 7 August 2023
The Joint Reply clarifies that Public Participation Hearings are not “unique” to this Rulemaking and underscores that the CPUC has the right to order such hearings in any proceeding. The Reply concludes with an explanation of why the initial Motion is not premature and should be granted.

CPUC: ALJ Ruling on Implementation Pathways for Income Graduated Fixed Charges  — Opening Comments on ALJ Ruling  | 31 July 2023
The Clean Coalition’s comments explain why our modest fixed charge proposal will guarantee savings for low-income residents and is the most practical proposal to implement. We underscore that high fixed charges will reduce the incentive for electrification and reward those using more energy with less efficient appliances, both of which are antithetical to the values held by the Commission. Finally, we argue that the Clean Coalition’s proposed fixed charge contains the only truly ‘fixed’ components that should be included in a fixed charge, meaning there should not be multiple iterations of new fixed charges moving forward.

CPUC: ALJ Ruling Setting Aside the Record and Questions on Cost-Effectiveness  — Opening Comments on ALJ Ruling  | 31 July 2023
The Clean Coalition’s comments note that the Net Value Billing Tariff (CCSA’s proposal) does not result in a cost shift and underscore that any cost-effectiveness tests must consider the full value created by Community Solar projects, including the additional value from infill solar projects as compared to ground mount solar projects. We advocate for a virtual storage pairing option to maximize the savings from economies of scale—via large energy storage (greater than the 4-hour requirement in CCSA’s proposal)—and increase the benefits of each project on the broader grid. Finally, our comments justify the value stack for Local Solar, showing that when considering the value created by avoiding Transmission Access Charges (TAC) and the Power Charge Indifference Adjustment (PCIA), remote wholesale generation is actually more expensive than truly Local Solar.

CPUC: Questions on Part 1 of the Electrification Impacts Study  — Opening Comments  | 14 July 2023
The Clean Coalition’s comments support the work that Kevala has done in Part 1 of the Electrification Impacts Study and urge the CPUC to consider analyzing the ratepayer savings that would be created by the widespread deployment of Community Microgrids and a Distribution System Operator to operate/optimize the grid.

CPUC: Public Participation Hearings about Income Graduated Fixed Charges  — Joint Motion for Public Participation Hearings  | 13 July 2023
The Joint Parties’ Motion for Public Participation Hearings requests that the CPUC hold eight Public Participation Hearings across PG&E’s, SCE’s, and SDG&E’s service territories, as well as convening customers of the small-jurisdictional utilities. The Motion seeks relief for the vast majority of the public, who have strong opinions about a residential income graduated fixed charge but have not been able to participate in the complex regulatory process occurring at the CPUC. Public Participation Hearings are common in any proceeding seeking a significant changes to rates; a fixed charge will result in substantial changes in the monthly bills of ratepayers, who deserve to have their voices heard.

CPUC: Ex parte communication  — Presentation for Commissioner Houck’s office | 28 June 2023
The Clean Coalition’s presentation to Commissioner Houck’s office explained why a successful Community Solar program must have appropriate pricing for infill projects (deployed on rooftops, parking lots, and parking structures) and that infill projects create greater value than ground mount solar projects. We discussed exemptions from the Power Charge Indifference Adjustment (PCIA), Transmission Access Charges (TAC), defined Local Solar, and explained the economic benefits of infill projects (including job creation, using brownfield sites, additional reliability, and resilience). A similar slide deck was presented to representatives from Commissioner Reynolds, Commissioner Douglas’, and President Reynolds’ offices in the last three weeks.

CPUC: Update on Commission General Order 131-D  — Opening Comments on Order Instituting Rulemaking | 22 June 2023
The Clean Coalition’s comments on the order instituting rulemaking urge the Commission to require a benefit cost analysis for each transmission project that includes a calculation of the lifetime costs the ratepayers will have to cover should a project move forward and any possible alternative distributed solutions.

CPUC: Solar on Multifamily Affordable Housing (SOMAH)  — Reply Comments on ALJ Ruling Inviting Comments on Potential Modifications to SOMAH | 16 June 2023
The Clean Coalition’s reply comments support program modifications to enable deployments of storage and to allow new and existing master metered buildings, primarily for resilience. We also support improving the interconnection process by designating a single point of contact at each of the IOUs.

CPUC: High DER Track 1  — Reply Comments on ALJ Ruling and Questions on Phase 1 Track 1 | 5 June 2023
The Clean Coalition’s reply comments support GPI/IREC comments on the need for more effective and granular ICA data and maps. We then urge the Commission to use a longer distribution planning horizon, collect more data on interconnection application withdrawals, account for secondary distribution infrastructure in the distribution planning process (DPP), and continue to consider resilience in the DPP.

CPUC: Demand Flexibility  — Rebuttal Testimony on Party Proposals | 2 June 2023
The Clean Coalition’s Rebuttal Testimony asks the Commission to approve our rebuttal proposal. We note that SEIA has the only reasonable proposal for an Income Graduated Fixed Charge (IGFC) of the nine parties that submitted proposals in Opening Testimony. Our testimony builds on SEIA’s model by proposing an ideal IGFC that both is easy to implement and results in savings for low-income customers. We conclude by analyzing a report by Flagstaff Research on the flaws of IGFC proposals made by the Joint IOUs, Cal Advocates, and NRDC/TURN and explain how an IGFC that is too high negates the benefits of electrification.

CPUC: Green Tariff Review Applications  — Reply Brief | 30 May 2023
The Clean Coalition’s Reply Brief supports the Coalition for Community Solar Access’ Net Value Billing Tariff (NVBT). We explain why SCE’s legal challenge should not be persuasive to the Commission, suggest an exemption from Transmission Access Charges and the Power Charge Indifference Adjustment, explain the value of auto-enrolling customers, and detail why it is necessary to solicit additional information from parties before the proceeding record is complete.

CEC: IEPR Workshops on Interconnection  — Comments on May 4th and 9th Interconnection Workshops  | 23 May 2023
The Clean Coalition lauds the CEC for hosting two effective workshops and conveys the need to further streamline interconnection to ensure that decarbonization/electrification occurs on time. We discuss the need to streamline WDAT interconnection and implement the Clean Coalition’s Fixed Fee, Utility Pays (FixUP) proposal, address the need for better data collection on reasons for interconnection attrition, mention the potential for automation of interconnection processes, and highlight the key role that ICA data will have to play in interconnection if validated for accuracy/increased granularity.

CPUC: High DER Track 1  — Opening Comments on ALJ Ruling and Questions on Phase 1 Track 1  | 22 May 2023
The Clean Coalition’s comments support improving the accuracy of ICA data and extending the planning horizon for distribution planning. We support a discussion that considers a future with a Distribution System Operator and a pathway of upgrades that will enable complete electrification in time to achieve the state’s energy goals. We make the point that distribution planning cannot occur in a silo and must consider solutions that create the greatest value for the ratepayers rather than the lowest immediate cost. In addition, we address the need for community-focused planning to enable resilience solutions, the importance of viewing each incremental DER deployment as a step toward deploying Community Microgrids, and the fact that ensuring disadvantaged communities receive the necessary funding to achieve equity/ESJ goals must be a priority.

CPUC: Green Tariff Review Applications  — Surrebuttal Testimony  | 28 April 2023
Clean Coalition’s surrebuttal testimony addresses the flaws with SCE’s attacks on our position that Transmission Access Charges (TAC) should not be assessed on Community Solar Energy by noting that Community Solar value is intended to be commensurate with Net Energy Metering (which does not assess TAC for onsite generation) and explains why SCE’s claim that interconnection reform is not necessary is unreasonable given the lack of success with past programs. We also refute SDG&E’s claim that CCSA’s proposal has no merit by proving how the Clean Coalition’s modifications proposed in rebuttal testimony would address each issue that SDG&E raised.

CPUC: Data Access and DER Programs Order Instituting Rulemaking  — Comments on ALJ’s Ruling Seeking Comments on Societal Cost Test and Air Quality Research | 28 April 2023
Clean Coalition’s comments strongly urge the Commission to adopt a Societal Cost Test (SCT) as the primary cost-effectiveness test due to the importance of externalizing costs that disadvantaged communities have been shouldering the brunt of for decades. We use the example of resilience (via the Clean Coalition’s VOR123 and RES) to show that societal benefits have a nonzero value that can be—and have been—quantified for individual facilities as well as a grid area. We also advocate for use of a High Social Cost of Carbon, the inclusion of an out-of-state methane adder, suggest that “society” should limited to California, and request that the Air Quality results should only be included in a SCT if they are remodeled using modern values (that account for recent inflation).

CPUC: Green Tariff Review Applications  — Rebuttal Testimony on Party Proposals | 7 April 2023
Clean Coalition’s rebuttal testimony supports the Coalition for Community Solar Access’ (CCSA’s) Net Value Billing Tariff (NVBT) proposal for a Successor Community Solar program. We offer a few modifications, including that projects should be on the same distribution area as (or within 5 miles of) subscribers and that subscribed energy should be exempt from Transmission Access Charges (TAC) and the Power Charge Indifference Adjustment (PCIA). Our rebuttal testimony concludes by underscoring the value of autoenrollment and the need for streamlined front-of-meter (FOM) interconnection.

CPUC: Demand Flexibility  — Comments on Proposed Decision Adopting Electric Rate Design and Demand Flexibility Design Principles | 6 April 2023
Clean Coalition’s comments are supportive of the Proposed Decision, though we request that the Commission makes two small changes. The first is adding the word “resilience” to Electric Rate Design Principle V and the second is adding the phrase, “required to deliver energy to the end-user,” to the end of Demand Flexibility Design Principle III.

CPUC: Net Energy Metering — Reply Comments on ALJ’s Ruling and Questions | 4 April 2023
Clean Coalition’s reply comments urge the Commission to adopt property-level netting for VNEM systems, support the deployment of storage and microgrids, and adopt Ivy Energy’s proposal. We also note that VNEM provides unique benefits including on-site energy usage, differentiate VNEM from the state’s Community Solar projects, and defend the avoided transmission value provided by VNEM systems against statements made by the Joint IOUs.

CPUC: Net Energy Metering — Comments on ALJ’s Ruling and Questions | 21 March 2023
Clean Coalition’s comments support maintaining virtual billing for the V-NEM tariff and encouraging paired installations of paired storage via a resilience adder and pathway for deploying single facility microgrids. We also request that the Commission consider increased compensation for NEM-A facilities based on the benefits they provide or an option to reduce demand charges.

CEC: 2023 Integrated Energy Policy Report (IEPR) Update — Comments on Scoping Memo | 17 March 2023
Clean Coalition’s comments on the 2023 IEPR Scoping Memo laud the Energy Commission for choosing to focus on interconnection and distinguishing between transmission and distribution-level interconnections. We lay out the case for front-of-meter interconnection reform using firsthand experience with the VGES project and other policy-analyses we conducted before offering a substantial number of WDAT-related interconnection reforms. Clean Coalition comments finish with an explanation about the need for template Single Line Diagrams for Title 24 Zero Net Energy facilities seeking Rule 21 interconnections as well as new Rule 21 configurations that allow distributed generation to provide distribution grid services.

CPUC: Microgrid Incentive Program Proposed Decision — Reply Comments on the MIP Proposed Decision | 6 March 2023
Clean Coalition’s reply comments urge the Commission to better prioritize the needs of Disadvantaged Vulnerable Communities by providing larger up-front grants and creating a determinative procurement process that will ensure a strong application definitively results in a deployed Community Microgrid.

CPUC: Sunnova Community Microgrids Application Proposed Decision — Opening Comments on Proposed Decision Approving Public Advocates Office Motion to Dismiss Sunnova Community Microgrids Application | 6 March 2023
These joint comments on the Proposed Decision express disappointment that the CPUC is choosing to dismiss the Application without any proper hearings, particularly given the widespread support for Community Microgrids and the benefits that these projects could bring to the community and grid. We urge the CPUC to throw this PD away and give Sunnova the opportunity to present its case in a full proceeding.

CPUC: Microgrid Incentive Program Proposed Decision — Opening Comments on the MIP Proposed Decision | 1 March 2023
Clean Coalition urges the CPUC to apply lessons learned from the lackluster Community Microgrid Enablement Program, including the need for fixed interconnection timelines, developer certainty, and a 36 month timeline between the signing of the Microgrid Operations Agreement and the Commercial Operations Date. We also urge the CPUC to approve a heat map that make eligibility criteria crystal clear and suggest that the maximum amount of funding for a pre-application grant should be increased from $25,000 to $100,000.

CPUC: Green Tariff Review Applications — Presentation on Clean Coalition Feed-In-Tariff Proposal for the Green Tariff Programs | 27 February 2023
Clean Coalition’s presentation explains why a Feed-In-Tariff with market responsive pricing, a dispatchability adder, and fixed interconnection is the most effective procurement method and should be used as the structure for the next iteration of the Green Tariff.

CEC: SB 846 Diablo Canyon Extension Analysis — Comments on Draft Report | 21 February 2023
Clean Coalition comments underscore the value of local solar in reducing: peak transmission usage, line losses, congestion, and transmission wear & tear. Our comments detail the importance of WDAT interconnection reform by laying out specific lessons learned from the Clean Coalition’s Valencia Gardens Energy Storage project.

CEC: DEBA Framework — Comments on January 27 DEBA Workshop | 17 February 2023
Clean Coalition demonstrates the need for an effective procurement process that enables developers to maximize the use of built environments for solar and solar+storage deployments. We urge the Energy Commission to invest in emerging grid management technologies (e.g., DERMS, d-STATCOMS, etc…) and make the case for deploying microgrids in three key areas: Solar Microgrids at schools, Community Microgrids at Load Pockets, and Single Parcel Microgrids that span multiple meters.

CEC: Draft Clean Energy Reliability Investment Plan (CERIP) Report — Comments on Draft CERIP Report | 16 February 2023
Clean Coalition’s comments urge the Energy Commission to address the need for WDAT interconnection reform and allocate money for the efficient deployment of microgrids. We also ask that the Energy Commission to consider speeding up the process for awarding deliverability and include distributed generation in the Integrated Resources Planning process.

CPUC: Application for Rehearing of D. 22-12-056 — Response to Application for Rehearing | 2 February 2023
Clean Coalition’s response urges the Commission to approve the Application for Rehearing of D. 22-12-056 and clearly demonstrates that the Commission’s analysis and reasoning in the Decision is incongruous with Public Utilities Code section 2827.1(b), legislative reports (SB 100 and SB 695), and the Commission’s own guiding principles in the Environmental Social Justice (ESJ) Action Plan and Distributed Energy Resources (DER) Action Plan 2.0.

CPUC: Data Access and DER Programs Order Instituting Rulemaking — Reply Comments on OIR on Data Access and DER Programs | 24 January 2023
Our reply comments underscore why a Societal Cost Test is necessary to value existing externalities and achieve the Commission’s goal of considering ESJ/DAC needs in the energy planning process. We also explain why including distributed energy resources (DER) in the Integrated Resources Plan (IRP) will help the state better consider cost-effectiveness of resource portfolios by including the actual cost of delivering energy to the end user.

CPUC: Demand Flexiblity Scoping Memo — Opening Brief on AB 205 Statutory Interpretations | 23 January 2023
Clean Coalition’s succinct Opening Brief explains that a fixed charge must not be viewed as a silver bullet solution to make rates affordable, since the majority of infrastructure-related costs should be assessed on a volumetric basis. Only public purpose program charges, billing administrative costs, metering costs, line transformer costs, and secondary voltage charges should be considered for a fixed charge. We also mention that ratepayers should be properly compensated for energy efficiency and DER deployment; a fixed charge should not punitively tax customers adopting electrification measures.

CPUC: Green Tariff Review Applications — Direct Testimony and Party Proposals | 20 January 2023
Clean Coalition testimony shows that the Green Tariff programs have not been successful at adding capacity and subscribers due to the disadvantages of the RFO process, a lack of focus on streamlined front-of-meter interconnection, and the over-complicated nature of the programs. We recommend a Feed-In-Tariff with a dispatchability adder and market responsive pricing as the most effective way to ensure that procurement matches subscriber rates. We note that the PCIA should not be included in the FIT rate and Green Tariff-customers should not be assessed Transmission Access Charges.

CPUC: Data Access and DER Programs Order Instituting Rulemaking — Comments on OIR on Data Access and DER Programs | 9 January 2023
Our comments highlight the importance of developing a Societal Cost Test, urge the Commission to make improve data sharing through increased transparency, and request parity among the IOUs when it comes to the Avoided Cost Calculator and valuing distributed energy resources.

CPUC: Demand Flexiblity Scoping Memo — Reply Comments on Phase 1 Assigned Commissioner’s Scoping Memo and Ruling | 4 January 2023
Our comments support amendments to the Rate Design Principles made by 350 Bay Area and The Climate Center, suggest a Critical Peak Pricing scheme, and underscore the need for greater data sharing. We also discuss the need to level the playing field for demand-side resources.

2022

CPUC: Draft Integrated Energy Policy Report — Comments on Draft IEPR | 7 December 2022
Our comments request that the Energy Commission prioritize a cost-benefit analysis that fully values externalities – such as the value of resilience – and work with the Public Utilities Commission to finalize a Societal Cost Test. We also propose consideration of solar, solar+storage, and Solar Microgrid deployments at schools as an equity issue, suggest that the Energy Commission should consider targeted deployments of Distributed Energy Resources (DER) to maximize savings, and pose a few questions that we believe should be included to ensure a complete analysis of DER occurs in the final IEPR.

CPUC: Net Energy Metering Proposed Decision — Reply Comments on Proposed Decision | 5 December 2022
Clean Coalition’s reply comments suggest that the Commission wait to approve a Successor Tariff until all data assumptions and modeling is updated and request that data monitoring of the Successor be carried out on an annual basis. We also urge the Commission to change the oversizing allowance from 150% to 175% and note that the value of NEM deployments will increase when they are optimized as part of an aggregation or Community Microgrid.

CPUC: Demand Flexiblity Scoping Memo — Opening Comments on Phase 1 Assigned Commissioner’s Scoping Memo and Ruling | 2 December 2022
Clean Coalition comments support the removal of transmission charges (in the form of Grid Benefits Charge) and lambast the Commission for considering a proposal that doubles payback periods and slashes the export compensation rate by 75%. We note that the PD puts the Commission in a difficult position because it does not create a clear standard that can be used to evaluate it as successful, since it was modeled using different analyses from the Lookback Study, the first PD, and the party proposals. Most importantly, we address the fact that the cost shift argument overestimates the costs and underestimates the benefits of NEM, without considering Societal Benefits.

CEC: Clean Energy Alternatives for Energy RFI — Response to Request for Information | 30 November 2022
Clean Coalition comments provide context about the need to level the playing field for demand-side resources by fixing the market distortion caused because Transmission Access Charges are metered at the customer meter rather than at the transmission-distribution substation and urge the Commission not to adopt any fixed charge that is discriminatory toward ratepayers adopting electrification measures. We also recommend that both sets of Staff Guidelines should be adopted after incorporating party input and propose a few amendments.

CPUC: Net Energy Metering Proposed Decision — Opening Comments on Proposed Decision | 30 November 2022
Clean Coalition comments support the removal of transmission charges (in the form of Grid Benefits Charge) and lambast the Commission for considering a proposal that doubles payback periods and slashes the export compensation rate by 75%. We note that the PD puts the Commission in a difficult position because it does not create a clear standard that can be used to evaluate it as successful, since it was modeled using different analyses from the Lookback Study, the first PD, and the party proposals. Most importantly, we address the fact that the cost shift argument overestimates the costs and underestimates the benefits of NEM, without considering Societal Benefits.

CPUC: Avoided Cost Calculator Petition for Modification — Response to Joint Parties Petition for Modification on the 2022 Avoided Cost Calculator | 2 November 2022
The Clean Coalition response supports the Petition for Modification to exclude load-increasing DER from the DER removed for the No New DER counterfactual. We note that removing all load-increasing DER will result in a smaller-than-necessary portfolio for the Preferred System Plan, will lead to undercounting for DER valuation, and that the Commission should follow the same caution exhibited for ascribing avoided transmission values to the three IOUs.

CPUC: Sunnova Community Microgrids Application — Response to Sunnova Community Microgrids Application | 10 October 2022
Clean Coalition hails Sunnova’s Community Microgrid application as a step forward toward commercializing Community Microgrids through a non-investor-owned utility company that constructs housing communities to benefit from the resilience and clean energy, shoulders the liability of reliable service by forming a micro-utility, and avoids any concerns of affordability/cost-shifting.

CEC: Façade-Integrated Solar — Comments on Emerging Technologies for the 2022 IEPR | 14 September 2022
Clean Coalition comments introduce Façade-Integrated Solar and underscore reasons that it is more appropriate to categorize Façade-Integrated Solar as an energy efficiency measure rather than as generating resources. We request that Façade-Integrated Solar is included in the Emerging Technologies section of the IEPR as an energy efficiency measure.

CPUC: Informal Comments on August 23 Workshop — Reply Comments in Response to August 23 Workshop | 9 September 2022
In these joint reply comments, we support comments by the Green Power Institute that listening sessions should consider current and future barriers to DER adoption and reiterate the need for a joint community engagement plan that adheres to guiding principles.

CPUC: Informal Comments on August 23 Workshop — Opening Comments in Response to August 23 Workshop | 31 August 2022
In this joint filing we request that the CPUC work with the CEC to create a joint outreach plan to solicit ratepayer opinions on a High DER future. We provide specific questions that the Commission should ask in listening sessions and provide examples of ways that DER can benefit communities.

CPUC: Microgrid Incentive Program Staff Proposal — Reply Comments on ALJ Ruling and Staff Proposal | 19 August 2022
In reply comments, the Clean Coalition reiterates the need to launch the Microgrid Incentive Program as soon as possible, given the dire need for resilience in California. Our comments also rebut statements by the Investor-Owned Utilities about the difficulty of creating a heat map for eligibility criteria through the work of Bethany Kwoka, a graduate student at UCSD.

CEC: Community Energy Resilience Investment Program — Clarifying questions on opening presentations | 18 August 2022
Clean Coalition comments ask clarifying questions about eligibility for the granting process and types of resources that qualify for the grant.

CPUC: Microgrid Incentive Program Staff Proposal — Opening Comments on ALJ Ruling and Staff Proposal | 5 August 2022
Clean Coalition comments support amending the Microgrid Incentive Program to make it as determinative as possible. We suggest that the Commission add a specific point threshold so that developers know that strong applications will lead to the deployment of Community Microgrids and specify the layers of information that need to be included in a useful heat map.

CPUC: Bloom Energy Petition for Rulemaking — Petition for Rulemaking | 25 July 2022
The Clean Coalition supports Bloom Energy’s Petition for Rulemaking to create a resiliency/reliability capacity tariff, albeit with a few changes. We recommend lowering the number of baseline hours of consecutive exports to 10 and primarily relying on renewable resources (or green hydrogen) to effectively more utilize microgrids and speed up the commercialization of the technology across the state.

CPUC: Net Energy Metering — Reply Comments on ALJ Ruling | 1 July 2022
The Clean Coalition’s reply comments lay out reasons why applying nonbypassable charges to gross consumption of Net Metered systems is an overreach by the PUC, one that would further damage the economics of the Net Billing Tariff (NEM 3.0) and will set a terrible precedent for future DER programs. We address logical fallacies made by other parties, namely the Joint Utilities and NRDC, before returning to Facade Integrated Solar as an example of how generation that is produced and consumed on-site is functionally similar to energy efficiency.

CEC: DER Order Instituting Information (OII) — Comments on Kickoff Workshop | 17 June 2022
In these opening comments on the Order Instituting Information on Distributed Energy Resources (DER) in California’s Energy Future, the Clean Coalition poses a series of important questions to guide the focus of the proceeding. We consider what role DER will play in California’s energy transition, how to maximize the value of DER, the mechanisms necessary to cost-effectively procure DER, how DER should be included in the grid planning process, whether DER have a level playing field compared to other resources, and the role that interconnection plays in DER procurement. Clean Coalition comments also asks the CEC to reflect on the outcomes of this proceeding and whether lessons learned will be sent to the legislature (if significant changes are required).

CPUC: Net Energy Metering — Opening Comments on ALJ Ruling Setting Record Aside and Taking Comments | 10 June 2022
In opening comments, the Clean Coalition takes a strong stand against extending nonbypassable charges to gross consumption of NEM facilities. We demonstrate that self-consumption is similar to energy efficiency since no energy utilizes the utility grid and use the example of Facade-Integrated Solar as a case study, first showing the similarities with energy efficiency and then backing up the claim that Facade-Integrated Solar should be exempt from NEM/interconnection rules.

CPUC: Avoided Cost Calculator (IDER) — Reply Comments on Proposed Decision | 26 April 2022
In reply comments, we reiterate our support for a stronger avoided transmission value by requesting that the Commission assign an interim value for SCE, calling for an “unspecified transmission value” to consider the value of deferring non-planned transmission upgrades and urging the Commission to deny PG&E’s proposal to remove the word “uncontested” from the findings of fact. We also scrutinize the Coalition of Utility Employee’s proposal to cut the avoided distribution value by 98% and request that the Commission prioritize accuracy over harmonizing the Avoided Cost Calculator with the Integrated Resource Planning process.

CPUC: Avoided Cost Calculator (IDER) — Opening Comments on Proposed Decision | 19 April 2022
In opening comments, the Clean Coalition supports updated avoided transmission values for PG&E, but requests that the PUC adopt an interim value for SCE until a full calculation can be completed. We also underscore the need for a grievance process to remedy egregious errors if the Commission removes the minor update process and suggest that any gas forecast prices need to take short-term price fluctuations into account.

CAISO: 20-Year Transmission Outlook — Comments on Draft Report | 22 February 2022
In comments, the Clean Coalition praises the creation of a long-term transmission roadmap, albeit we advocate that the final report should include potential investments in distributed energy resources (DER) as part of the scenario planning process to prevent over-investment in transmission, keeping electric rates from skyrocketing. Our comments detail the ways in which DER can avoid transmission investment and demonstrate, via the Vibrant Clean Energy study, the significant ratepayer savings that come from a balanced grid planning process.

CPUC: Microgrids — Reply Comments on Microgrid Incentive Program Implementation Plan | 28 January 2022
In reply comments, the Clean Coalition underscores the need to extend the project commercial operations date, requests specified interconnection timelines, advocates for a single program website and suggests that the application scoring should reward applicants for projects that serve more customers instead of capping points in that category.

CPUC: Microgrids — Opening comments on Microgrid Incentive Program Implementation Plan | 14 January 2022
In opening comments, the Clean Coalition requests changes to make the Microgrid Incentive Program a deterministic program, where applicants will have certainty that a high application score will lead to approval and the eventual deployment of a Community Microgrid. To ensure this is possible, we advocate for allowing expedited approval of applications fully funded by third parties, urge the IOUs to publish information about Application Intake Windows in advance and streamline interconnection to ensure applicants can achieve their initial commercial operations date.

CPUC: DER Deferral — Comments on Draft Resolution E-5190 | 14 January 2022
In comments on the Draft Resolution, the Clean Coalition supports the changes and requests a few amendments before the Commission approves a Final Resolution. We request uniformity among the three IOUs through the selection of a single Independent Evaluator, applaud the inclusion of a DERMS analysis and propose the inclusion of other emerging DER in the DER Deferral Pilots, such as d-STATCOMS.

CPUC: NEM — Reply comments on proposed decision | 14 January 2022
In reply comments, the Clean Coalition notes that the Commission incorrectly relies on the Ratepayer Impact Measurement test rather than the Total Resource Cost test as the main cost-effectiveness test (and does not use a Societal Cost Test at all). We also address the fact that the Commission’s focus on solar+storage adoption will lead to a drastically lower level standalone solar adoption in all communities and urge rejection of the PD based on lackluster consideration of the full range of party proposals related to energy storage.

CPUC: NEM — Opening comments on proposed decision | 7 January 2022
In opening comments, the Clean Coalition explains why the Proposed Decision will drive ratepayers away from using NEM by making non-export options more economical. We demonstrate that the proposed Grid Participation Charge is an illegal distortion of Transmission Access Charges, which should not be assessed to NEM customers, and critique an insufficient allowance for facilities preparing for electrification to oversize their PV system.

2021

CPUC: Renewable Market Adjusting Tariff — Reply comments on proposed decision | 6 December 2021
In reply comments, the Clean Coalition underscores the importance of using Time of Delivery factors to incentivize the export of energy during peak grid periods and explains why it is necessary for SDG&E to reopen its ReMAT program to meet state procurement requirements.

CPUC: Renewable Market Adjusting Tariff — Opening comments on proposed decision | 30 November 2021
In opening comments, the Clean Coalition supports aspects of the Proposed Decision, including the addition of co-located storage, reopening SDG&E’s queue, notifying queue customers of tariff changes, and expanding eligibility to facilities with shared transformers. However, we disagree with the Commission about flexible product categories and instead request a single product category combined with time of delivery factors to optimize the program with the addition of co-located storage.

CEC: Research on Valuation of Investments in Electricity Sector Resilience — Written comments for the docket | 19 November 2021
Clean Coalition comments urge the Energy Commission to consider our value-of-resilience (VOR) methodology, VOR123, and Resilient Energy Subscription (RES) market mechanism in its research on the valuation of investments in electricity sector resilience. VOR123 and RES will provide a pathway to the widespread deployment of Solar Microgrids and Community Microgrids, as well as helping to finance and expand Community Microgrids.

CPUC: Microgrids for Emergency Reliability — Reply comments on the Track 4 Phase 1 proposed decision | 16 November 2021
Clean Coalition reply comments remind the Commission that the core principle of this proceeding is to increase the commercialization of microgrids and that the decision making process should continue to prioritize input from local governments and tribal communities. With that in mind, we urge the Commission to approve the Regional Microgrid Pilot Program proposed by the County of Los Angeles.

CPUC: Microgrids for Emergency Reliability — Opening comments on the Track 4 Phase 1 proposed decision | 10 November 2021
Clean Coalition comments critique the Proposed Decision for ignoring the vast majority of party proposals and failing to reduce the inhibitions to the widespread proliferation of microgrids. We urge the Commission to consider the proposal made by the County of Los Angeles to deploy Critical Facility Community Microgrids and then explain why a Resilient Energy Subscription (RES) is the missing piece needed to cost-effectively expand a Community Microgrid at the cost of service.

CPUC: Microgrids for Emergency Reliability — Opening comments on the Track 4 Phase 1 proposed decision | 10 November 2021
In these Joint Comments, parties lambast the Commission for taking a step in the wrong direction by approving fossil-fuel generation. In addition, comments point out the inherent cost shift in SDG&E’s proposal and decry the Commission’s choice to reject the majority of party proposals as a sign that it isn’t properly carrying out the mandate laid out in the Governor’s Emergency Proclamation.

FERC: Transmission Planning — Reply comments | 9 November 2021
The Clean Coalition advocates that the Federal Energy Regulatory Commission’s rulemaking on regional transmission planning prioritize transparency, precise cost allocations, and transitioning to a two-way grid powered by distributed energy resources (DER). As an example, our comments point to the current market distortion caused by the inaccurate assessment of Transmission Access Charges (TAC) at the customer meter rather than at a transmission-distribution substation. We also note that even as transmission costs continue to drive up electric rates, the majority of utility transmission projects (greater than 80% in the case of PG&E from 2016-2019) are self-approved. Building an efficient grid requires balancing state and local needs in an effort to supply clean energy at the lowest cost to the consumers, not just building more unvetted transmission infrastructure.

CPUC: Draft DER Action Plan 2.0 — Informal comments | 8 October 2021
In these informal comments, the Clean Coalition calls on the Commission to acknowledge the value of DER and offers a series of action items, which can mostly be implemented in the next year and a half, to speed up the transition to a two-way grid. We focus on policy revisions that will change the planning process, including reforming the DIDF to include all clean DER, improving ICA/Data Portals to benefit developers, automating BTM interconnection, streamlining FOM interconnection, and implementing Performance Based Regulation in the near-term.

CPUC: High DER OIR — Reply comments on OIR | 7 October 2021
In these reply comments, the Clean Coalition requests that the proceeding be structured in parallel tracks, allowing low-hanging-fruit-solutions to be implemented quickly, while longer systematic change is properly studied. We suggest addressing ICA issues and Performance Based Regulation in the short-term and the value of resilience, DER opportunities assessment, and a solution to Transmission Access Charges in the long-term.

CPUC: Microgrids — Reply to Opening Comments in Response to Emergency Proclamation Proposals | 1 October 2021
In reply comments, we recommend the approval of behind-the-meter distributed generation aggregations and Community Microgrids rather than continuing to rely on temporary contracts with fossil fuel generators. Due to looming reliability concerns, we also support a relaxation of Rule 18/19 rules on private energy sharing between adjacent properties and continue to stress the importance of swift interconnection reform.

CPUC: Proposed Preferred System Plan — Opening comments in response to ALJ ruling seeking questions | 27 September 2021
The Clean Coalition comments express surprise that the Load Serving Entity’s Integrated Resource Plans did not meet either reliability or GHG reduction goals. We criticize the proposed Preferred System Plan as failing to consider DER as an alternative to transmission-interconnected resources, particularly with the increasing demand for resilience. Opening comments conclude by briefly introducing our Resilient Energy Subscription (RES) proposal, a way to fund Community Microgrids, which add a layer of local resilience and reduce congestion on the transmission system.

CPUC: Microgrids — Opening comments in response to emergency proclamation proposals | 24 September 2021
Using examples from the VGES Front-of-Meter Energy Storage Interconnection Case Study, Clean Coalition comments underscore the need for front-of-meter interconnection reform to truly enable Community Microgrids. We also urge the Commission to consider a joint report we drafted with the Green Power Institute on Automation on the behind-the-meter interconnection process.

CPUC: NEM 3.0 — Reply briefs | 22 September 2021
In reply briefs the Clean Coalition explains that the Successor Tariff should be crafted based on the intent of the original legislation: to ensure the sustainable growth of renewable technologies. We urge the Commission not to push ratepayers away from NEM with punitive fees for transmission and access to the grid and instead maximize benefits to the grid with a Feed-In Tariff for larger NEM systems. Our comments support extending VNEM, reforming NEM-A, and guaranteeing a reasonable payback period for all NEM systems.

CPUC: Order Instituting Rulemaking to Modernize the Electric Grid for a High DER Future — opening comments | 16 August 2021
Clean Coalition comments applaud the CPUC for developing a streamlined proceeding to manage the future of DER and optimize a two-way grid. We advocate for a full study of a DSO model (including all ownership models), the importance of reconsidering Transmission Access Charges/avoided transmission values, and creating a framework to balance all solutions as part of the distribution planning process.

CPUC: Proposed Decision on Order Closing Rulemaking 14-10-003 — reply comments | 26 July 2021
Clean Coalition reply comments support the opening comments of 350 Bay Area in requesting a full and detailed list of the proceeding’s history. We argue that the new High DER Planning proceeding (R. 21-06-017) can only succeed with a thorough foundation of everything that has been completed or still needs to be finished from the IDER proceeding. We provide an example of the recent confusion over what constitutes a Minor Update versus a Major Update to the Avoided Cost Calculator as an opportunity to demonstrate where progress has been made in the IDER proceeding, but CPUC clarity is needed.

CPUC: NEM 3.0 Direct Testimony — rebuttal testimony | 16 July 2021
In Rebuttal Testimony, the Clean Coalition points out the absurdity of charging a Grid Benefits Charge (GBC) based solely on on-site consumption and explains why CPUC precedent requires the use of the Total Resource Cost test as one of the main tools to measure the cost-effectiveness of DER. Our testimony exposes the flawed assumptions involved in the creation of proposed GBCs and details the multiple ways in which DER can defer transmission buildout.

CPUC: Microgrids — reply comments | 6 July 2021
In reply comments the Clean Coalition notes that the CPUC has not done a comprehensive analysis of the benefits a microgrid provides, nor has a study of any costs to the grid been completed. As a result, the proceeding has been needlessly limited, and while the Proposed Decision is an important step forward, it is only a portion of much broader solution necessary to overcome the barriers to the commercialization of microgrids.

CPUC: Microgrids — opening comments | 29 June 2021
In these opening comments on the Proposed Decision, the Clean Coalition supports the proposed exemption for microgrids from capacity reservation charges, and urges the CPUC to take it a step further. We request that all emergency charging situations prior to widespread outages not be counted toward increased demand charges and suggest that verification of microgrids be dependent on the emissions from component resources. Comments conclude by suggesting that microgrids that export fully during the critical peak period of the day should receive a full exemption from non-bypassable charges.

CPUC: DER Deferral Evaluation and Performance Criteria Implementation Advice Letter — protest of AL 3780-E | 23 June 2021
The Clean Coalition protests the Joint Utility’s implementation plan, arguing that the Distribution Planning Advisory Group (DPAG) should hire the Independent Evaluator (IE) for the program and only choose to ramp down one of the two pilots if there is a request from both the utility and the IE. We also request an analysis of DERMS for each pilot, to ensure that short-term results do not count against the long-term success of DER deferral.

CPUC: ALJ Ruling Seeking Updated Information Regarding the Renewable Market Adjusting Tariff Program — reply comments | 23 June 2021
Clean Coalition reply comments explain why now is the right time to amend ReMAT in order to regain market confidence, request that the CPUC consider expanding program allocations, demonstrate the need to remove product categories, and implement time-differentiated TOD factors, and we urge the CPUC to adopt a locational adder.

CPUC: NEM 3.0 Direct Testimony — opening testimony | 18 June 2021
In our testimony, the Clean Coalition focuses on pushing back against a grid benefits charge, especially one that would charge NEM customer Transmission Access Charges. We also underscore how essential it is for ratepayers that the debate over the Successor Tariff is not limited to the residential aspect of the tariff, precluding changes to the way V-NEM, NEM-A, and larger NEM systems are billed.

CAISO: Aggregate Constraint Capabilities Final Draft Tariff — comments | 14 June 2021
The Clean Coalition lauds CAISO’s final tariff as enabling the use of software controls as a technique to impose separate output limits at the point of interconnection, allowing multiple off-takers from a single project. We use the example of the Clean Coalition’s Valencia Gardens Energy Storage (VGES) project to demonstrate that with an option for Aggregate Constraint Capabilities, the original two-battery energy storage system design could have moved forward, rather than requiring a shift to a single smaller energy storage system.

CPUC: Comments on Advanced DER & Flexibility Management Workshop | 11 June 2021
Clean Coalition comments support Energy Division’s Real Time Pricing Proposal as an important step toward achieving more granular and transparent energy costs that will reduce the barriers to market entry for ratepayers interested in renewable energy systems. In particular, we note the importance of using an avoided cost framework to properly value the benefits of distributed energy and of including a Value of Resilience. Comments also emphasize the importance of deploying Distributed Energy Resources Management Systems (DERMS) to manage DER in real time and respond accordingly, optimizing the function of a two-way grid.

CPUC: ALJ Ruling Seeking Updates Information Regarding the Renewable Market Adjusting Tariff Program — opening comments  | 9 June 2021
Clean Coalition opening comments advocate for the consolidation of the three ReMAT product categories into one large category with TOD multipliers to incentivize the deployment of co-located storage in order to maximize the value of energy exported to the grid. In addition, to ensure that full capacity is reached, we recommend that the CPUC change the definition of “fully subscribed,” remove de minimis status entirely, and reopen SDG&E’s ReMAT program.

CPUC: Avoided Cost Calculator (IDER) — reply comments  | 1 June 2021
In reply comments, the Clean Coalition poses three questions and correlates a “no” answer to each question as providing the CPUC with sufficient reason to reject the proposed 2021 Minor Update. First, is there a consensus among parties that the changes are minor? Second, was the CPUC-specified procedure for a Minor Update followed? Third, can the CPUC be sure all inputs are accurate and will not result in unforeseen consequences?

CPUC: Avoided Cost Calculator (IDER) — opening comments | 24 May 2021
Clean Coalition comments critique the CPUC for attempting to sneak major changes into the Avoided Cost Calculator during a Minor Update cycle. The changes, which slash the value of standalone solar by 70%, did not go through a thorough public evaluation by stakeholders and rely on untested/unapproved modeling tools. We address improper inputs to the model, including the use of temperature data from 2013 to model heat rates in 2030, and explain why the missteps result in a drastically lowered avoided cost of DER when compared to the 2020 ACC.

CPUC: NEM Fuel Cell Tariff  — reply comments | 17 May 2021
While the Clean Coalition acknowledges in comments that the NEM Successor Tariff should also apply to fuel cells, we strongly support proposals to require verification — via an independent inspector — to guarantee that no methane leakage is occurring before a facility is allowed to officially take serve under the tariff. We also support comments made by Protect our Communities Foundation advocating for the CPUC to request new acceptable greenhouse gas emission levels for fuel cells (from the California Air Resources Board).

CPUC: Rule 21 Track 1 Interconnection Proposed Decision  — reply comments | 3 May 2021
Clean Coalition reply comments argue that the proposed two-year timeline for soliciting new interconnection issues needs to be shortened to ensure that the CPUC does not fall further behind at creating regulation than in the past. Our comments also advocate for the creation of single-line diagrams for Zero Net Energy projects, to ready the Joint IOUs for the influx of interconnection requests from new constructions complying with energy efficiency mandates.

CPUC: Provider of Last Resort — opening comments | 26 April 2021
Clean Coalition opening comments acknowledge the importance of discussing details about how the provider of last resort will operate in California and suggest that guidelines and a tentative schedule for inter-agency cooperation should be set within 30 days of the prehearing conference.

CPUC: DER Deferral Evaluation and Performance Criteria — reply comments | 14 April 2021
Clean Coalition reply comments aim at ensuring the pilots are administered all the way through to the original deadlines approved by the CPUC; we agree with a statement made by Cal Advocates that the pilots should continue if there is any long-term pathway to success. Furthermore, we acknowledge that analysis of the pilots should consider how the value of a long-term program might change with the inclusion of Distributed Energy Resources Managements Systems, which can optimize the value of a DER aggregation that includes resources deployed on both sides of the meter.

CPUC: DER Deferral Evaluation and Performance Criteria — opening comments | 9 April 2021
Clean Coalition comments argue that the most important way to evaluate these new pilots is to gather as much data as possible to understand the big picture, including resource types for each project, changing market conditions, the number of deferral needs met each year, and the type of aggregators bidding to meet the demand. We also argue that resources should receive value for the system benefits they provide in addition to deferring the need for distribution upgrades, such as greenhouse gas reduction and avoided tranmission. Comments conclude by suggesting that the CPUC should evaluate whether allowing aggregations of resources on either side of the meter, rather than separate pilots for behind-the-meter and front-of-meter resources, would optimize the value of DER.

CPUC: Proposed Successor to the Net Energy Metering Tariff | 15 March 2021
The Clean Coalition party proposal focuses on a few key areas rather than outlining a full Successor Tariff. We advocate for the development of a Feed-In Tariff (FIT) similar to the LADWP FIT+ Pilot Program, argue that Transmission Access Charges (TAC) should not be included in the final list of non-bypassable charges in the Successor Tariff, and suggest that all meters participating in aggregations for NEM-A be exempt from demand charges. Comments touch on the need for valuing resilience for paired storage and the benefits of including a pathway for sites to over-generate in preparation for a load increase associated with electrification.

CPUC: Microgrid Track 3 Amended Scoping Memo and Questions — reply comments | 10 March 2021
Our comments focus on the fact that all parties agree that discussing microgrid exemptions to standby charges is premature without first quantifying the value-of-resilience (VOR). The Clean Coalition underscores the need for the Commission to approve standby-charge reform in the microgrids proceeding and calls for exemptions for small microgrids under 1 MW and critical community facility microgrids.

CPUC: Microgrid Track 3 Amended Scoping Memo and Questions — opening comments | 3 March 2021
Clean Coalition comments make it clear that discussing exemptions to standby charges without defining and quantifying the grid services a microgrid can offer — resilience, in particular — makes the debate much less meaningful and granular than it otherwise would be. We argue that standby charges are outdated and the concept of the utility as the “provider of last resort” does not account for the reliable service a microgrid provides. We conclude that the Commission needs to entirely reform standby charges and that exemptions should be granted for multiple different types of microgrids, including critical community facility microgrids, microgrids that provide grid services, and microgrids completely disconnected from the grid.

CPUC: Proposed Decision Directing PG&E, SCE, and SDG&E to Seek Contracts for Additional Power Capacity for Summer 2021 — reply comments | 2 February 2021
In reply comments, the Clean Coalition aligns with party positions arguing that this proceeding should be used to set the stage for long-term solutions deployed in 2022, 2023, and beyond. While we still push for the necessary prioritization of energy storage, we suggest that the Commission tie energy storage together with other renewable resources in the optimal configuration, a series of Community Microgrids. Comments include Clean Coalition analysis showing that Community Microgrids are a more economical investment than gas peaker plants.

CPUC: Proposed Decision Directing PG&E, SCE, and SDG&E to Seek Contracts for Additional Power Capacity for Summer 2021 — opening comments | 28 January 2021
Clean Coalition comments request that the Commission prioritize the procurement of energy storage over any investments in fossil fuel generation. We argue that energy storage is dispatchable and offers other benefits to the electrical system — resilience, a reduction in greenhouse gas emissions, and lower demand during peak hours — that fossil fuel generation cannot compete with.

CPUC: Proposed Decision Adopting Guiding Principles for the Development of the Successor to the Current Net Energy Metering Tariff — opening comments | 25 January 2021
The Clean Coalition argues that the Proposed Decision should include a guideline about promoting energy storage. Our comments demonstrate that if Principle 5 — using a technology-neutral approach — is amended to specify “eligible generation resources,” the addition of a guideline about energy storage will complement rather than conflict with it. Comments conclude by pointing out the need for the Commission to prioritize guidelines that create specific metrics to be used when judging the success of a tariff. We identify the guideline about “considering fair competition between electric service providers” as an example of one that is difficult to prove one way or the other.

CPUC: Proposed Decision Adopting Pilots to Test Two Frameworks for Procuring Distributed Energy Resources that Avoid or Defer Utility Capital Investment — opening comments | 25 January 2021
In opening comments, the Clean Coalition offers support for the two pilots, also suggesting that the Commission should consider making the pilots permanent during the mid-project review rather than waiting five years for the scheduled end of the pilots if clear benefits are evident early on. The mid-project review should consider ways to optimize aggregations, including combining behind-the-meter and front-of-meter projects. We urge the Commission not to forget the importance of Distributed Energy Management Systems, which the utilities are not required to develop in the current iteration of the Proposed Decision. Comments conclude with an argument for the inclusion of a market-adjusting cost cap and a discussion of two scenarios where the use of a Feed-In Tariff would greatly benefit the deferral tariff.

CPUC: Ruling Directing Responses to Questions on Rule 21 Working Group 4 Report and Issues 11 and 13 — reply comments | 8 January 2021
In these reply comments, the Clean Coalition replies to the three parties in opposition — California’s three investor-owned utilities — to the proposal we sponsored, which would require the creation of template single-line diagrams for Zero Net Energy (ZNE) facilities. We reiterate that the proposal is a simple but elegant solution for streamlining interconnection by proactively reducing the imminent increased demand on interconnection staff as an influx of ZNE applications are submitted.

CPUC: Microgrid Track 2 Proposed Decision Comments — reply comments | 4 January 2021
In this reply to opening comments, we agree with parties that the Commission should make a strong statement to the legislature about the need to change the over-the-fence rule (section 218(b) of the Public Utilities Code). We also concur with the Microgrid Resources Coalition about the need for clarify foundational definitions such as “commercialization” and “cost-shifting,” adding the “value of resilience” as another phrase that will change the outcome of the proceeding. We end with a request that the Commission further discuss the value of microgrid grid services and specify some of the unintended consequences that caused them to limit proposals during Track 2.

2020

CPUC: Microgrid Track 2 Proposed Decision Comments | 28 December 2020
Clean Coalition comments open with a strong critique of the Commission for rushing Track 2 of the proceeding, ultimately culminating with a Proposed Decision that does not achieve any of the goals listed in SB 1339 — commercializing microgrids and reducing greenhouse gases — and that does not even attempt to quantify the value-of-resilience (VOR). We make a number of suggestions, including calling for all critical facilities to be eligible for the Rule 18/19 exemption, asking for microgrid grid services and resilience to be valued in a microgrid rate schedule, and requesting that the utilities be held to a stricter standard for transitioning to renewable microgrids for substation-level backup power.

CPUC: Ruling Directing Responses to Questions on Rule 21 Working Group 4 Report and Issues 11 and 13 — opening comments| 18 December 2020
In opening comments, the Clean Coalition supports proposals that would reduce interconnection times related to anti-islanding studies, including a proposal requiring generation-to-load calculations to be performed with hourly profiles and a proposal to speed up the process by allowing applicants to hire utility-approved experts for a more detailed study. The majority of comments focus on responding to questions related to the proposal submitted by the Clean Coalition to require the creation of template single-line diagrams for Zero Net Energy facilities.

CPUC: Joint Assigned Commissioner’s Scoping Memo and Administrative Law Judge Ruling Directing Comments on Proposed Guiding Principles Related to Net Energy Metering | 11 December 2020
Clean Coalition reply comments on guiding principles for the Net Energy Metering (NEM) proceeding center around the need for a greater focus on sustainable growth of NEM projects in underserved communities, including promoting energy storage. We also request that the guidelines ensure that evaluation of NEM projects be based on the net benefits to the entire electrical system, not just the distribution system.

CPUC: Joint Assigned Commissioner’s Scoping Memo and Administrative Law Judge Ruling Directing Comments on Proposed Guiding Principles Related to Net Energy Metering | 4 December 2020
In opening comments, the Clean Coalition requests the inclusion of phrases in two guiding principles that will focus the proceeding on the impacts NEM has on the distribution and transmission systems and to ensure that the successor tariff will enable electrification in alignment with state policy. We also request the removal of the word “continue” from a third guideline to guarantee that the proceeding is not limited in discussions about solutions promoting equitable growth of renewable resources in all communities, especially low-income and disadvantaged communities.

CPUC: E-mail Ruling Introducing Distributed Energy Resources Tariff Staff Proposal and Directing Comments and Responses to Questions — reply comments | 11 November 2020
Clean Coalition reply comments center around refuting claims by Cal Advocates, SDG&E, and PG&E about the recklessness of including an over-procurement margin (since not all of the generation of a DER project will be used for deferral purposes), the utility preference that each IOU only be required to administer one of two deferral programs, and the opinion that DER aggregation is not yet commercially feasible.

CPUC: E-mail Ruling Introducing Distributed Energy Resources Tariff Staff Proposal and Directing Comments and Responses to Questions | 11 November 2020
In opening comments, the Clean Coalition commends the creation of a tariff that will allow utilities to leverage a combination of front-of-meter (FOM) and behind-the-meter (BTM) DER to defer the need for infrastructure upgrades on the distribution system. We argue that utilizing multiple sources of capital — including existing programs and private capital — will allow for the most efficient aggregations of projects to be deployed. Clean Coalition comments also suggest the need to properly assess Transmission Access Charges and advocate for a Feed-In Tariff as an ideal DER procurement mechanism.

CPUC: Presentation on Clean Coalition Proposal 19d in Rule 21 Working Group 4 | 16 October 2020
The Clean Coalition advocates for Proposal 19d, requiring the use of template single-line diagrams for Zero Net Energy Facilities. When a utility has 50 applications in a project category (e.g., NEM-paired storage, Rule 21 non-NEM export, Rule 21 grid services, etc.), they will be required to have a call with stakeholders within 90 days and publish the template diagram within 120 days of the stakeholder engagement. The proposal does not inhibit the utility review process or require duplicative efforts.

CPUC: Policy Questions on an Interim Approach for Minimizing Emissions from Generation during Transmission Outages — reply comments | 2 October 2020
The Clean Coalition supports proposals by Tesla and Sunrun to use solar microgrids for substation-level backup power and questions why their initial proposals were rejected by the Commission. Our comments also push back on PG&E’s assertion that diesel should be phased out over the next 7 years and requests that PG&E explain why existing proposals are not sufficient to proceed to an RFP.

CPUC: Rulemaking to Investigate and Design Clean Energy Financing Options for Electricity and Natural Gas Customers | 30 September 2020
The Clean Coalition advocates for the need to determine a standard value-of-resilience and suggests the Dispatchable Energy Capacity Services (DECS) market mechanism as two important value adders for electrification. Comments conclude by proposing our Electrification & Community Microgrid Ready (ECMR) guidelines as a way to transparently promote the standard costs associated with electrifying a facility in preparation for interconnection to a Community Microgrid.

CPUC: Order Instituting Rulemaking on Net Energy Metering Successor Tariff | 28 September 2020
The Clean Coalition’s comments suggest switching to inverter-based restrictions rather than generation-based restrictions and highlight the need to amend NEM to allow facilities with plans to electrify in the near term to oversize generation. For resilience purposes, the Clean Coalition calls for the removal of energy storage sizing limits.

CPUC: Policy Questions on an Interim Approach for Minimizing Emissions from Generation during Transmission Outages | 25 September 2020
The Clean Coalition lambasts the Commission for waiting to take action on the issue of substation backup power until August 2020, defaulting to the use of diesel fuel for 2021 after explicitly stating only three months earlier that it would only be acceptable for use in 2020. Instead of diesel fuel as a primary energy source, Solar Microgrids should be installed with diesel fuel as a secondary backup, to be disconnected as more PV resources are aggregated. Solar+storage resources provide everyday power and grid services that fossil fuel resources cannot, making them much more cost-effective in the long term.

CPUC: Proposed Decision Resuming and Modifying ReMAT — reply comments | 15 September 2020
The Clean Coalition reply to party comments supports the need for determining avoided cost using similar-sized RPS contracts, time-of-delivery factors, as well as adders for the value of resilience and locational pricing. Comments also specify the need for creating standards for co-located storage and explain why the use of price adjusting mechanisms is more effective than administratively set prices.

CPUC: Proposed Decision Adopting Recommendations from Working Groups Two, Three, and Subgroup — reply comments | 14 September 2020
Clean Coalition reply comments are in alignment with Tesla and CALSSA on a multitude of issues, including the need to lower standard fees to the level of NEM projects, the importance of designating one point person for each interconnection application, and a request that the Commission clarify the decision to remove the size limit for Fast Track eligibility. The Clean Coalition agrees that changing the size limit will only be effective if projects are eligible regardless of the available hosting capacity.

CPUC: Proposed Decision Resuming and Modifying ReMAT | 10 September 2020
Clean Coalition comments decry the Proposed Decision for refusing to consider any party proposals and suggest that at best, the Proposed Decision leaves the door open for the creation of an optimal successor Feed-In Tariff (FIT). Comments include reasons why the Commission must consider properly assessing Transmission Access Charges (TAC) for ReMAT projects and should include adders for resilience and locational pricing. Moreover, the Clean Coalition lambasts the Commission for using the explicit language of PURPA as an excuse not to innovate or logically create a tariff.

CPUC: Proposed Decision Adopting Recommendations from Working Groups Two, Three, and Subgroup | 9 September 2020
Clean Coalition comments support the Proposed Decision as helping to reduce the uncertainty in the interconnection process through the removal of the size limit for Fast Track eligibility and suggests that the Commission approve a proposal to lower upfront fees. The latter section focuses on reasons why the Commission should adopt a proposal to incorporate a GPI/Clean Coalition Roadmap to automation as a way to proactively address the issues the proceeding will need to consider in the next few years as well as a proposal to designate a point person at a utility for interconnection applications of projects over 100 kWA.

CPUC: Community Microgrid Enablement Program | 8 September 2020
The Clean Coalition response supports PG&E’s Community Microgrid Enablement Program, lauding PG&E for taking a role as a community partner to deploy Community Microgrids. The program creates a framework that allows communities to identify their resilience needs, promoting the inclusion of as many customers as possible that can be supplied with 20 MW of renewable resources. The filing concludes with a few Clean Coalition recommendations to increase transparency for the benefit of local governments.

CPUC: Microgrid Track 2 — reply comments | 28 August 2020
Parties, including the Clean Coalition, consider the lack of focus in Track 2 on Community Microgrids and the need for a full microgrid compensation tariff to consider normal instances when a microgrid is not in an islanded mode. Comments strongly address the conservative nature of the proposals in the Staff Proposal, lambasting the Commission for slowing the pace of progress by delaying the definition for a value of resilience and failing to value the public benefit it provides.

CPUC: Distribution Resources Planning IComp AFR | 24 August 2020
The Clean Coalition argues that the Commission is violating the spirit of the Intervenor Compensation program by only focusing on customer status, refusing to consider the Clean Coalition’s substantial contributions to the proceeding. Doing so limits the participation of groups like the Clean Coalition, thus overstating the positions of the utilities, who prioritize rates of return. Second, the Clean Coalition argues that with California’s clean energy goals, the entire state is aligned with the renewable energy industry; since the Clean Coalition has always focused on distribution-level renewable resources and resilience, it should not be discounted from customer status.

CPUC: Microgrid Track 2 comments | 14 August 2020
The Clean Coalition comments focus on criticizing the Staff Proposal for the lack of a standard microgrid tariff, including any type of discussion on resilience and the Value of Resilience. Before getting to the Staff Proposal, the comments note the complete absence of logic in choosing to include a detailed concept paper and then not allow any comments on the Concept Paper into the record for Track 2. For the five proposals, the Clean Coalition supports ambitious positions that enable Community Microgrids and Feed-In Tariff-like pilot programs rather than the Commission’s typical conservative steps that kick the can further down the road.

CEC: IEPR comments | 30 July 2020
In this comment letter, the Clean Coalition advocates that the California Energy Commission (CEC) develop a Community Microgrid pilot in a comprehensive grid area or on a substantial feeder (containing critical facilities). A CEC-sponsored Community Microgrid pilot will run in parallel with the California Public Utilities Commission (CPUC) microgrid proceeding, forcing the CPUC to consider current market distortions, including the assessment of Transmission Access Charges and the lack of a standard value-of-resilience. The Clean Coalition offers the Goleta Load Pocket as an ideal location for the siting of a Community Microgrid pilot.

CPUC: ReMAT ruling — reply comments | 28 July 2020
In reply comments, the Clean Coalition aligns with other parties about the need to deny the Staff Proposal in favor of a two-track proceeding to temporarily apply the Renewable Market Adjusting Tariff (ReMAT) program with modifications and to create the ideal ReMAT program by the end of 2021. Comments also focus on considering existing Petitions for Modification (the Clean Coalition has two), the importance of considering co-located storage, and denying the IOU Proposal, which calls for pricing ReMAT contracts on all resources (e.g., fosil-fuel generation, not just RPS prices).

CPUC: Resuming and updating ReMAT — reply comments | 21 July 2020
This filing represents the Clean Coalition’s reply comments on the Renewable Market Adjusting Tariff (ReMAT) ALJ Ruling and Staff Proposal. The Clean Coalition comments take the approach that the Staff Proposal must be denied since the administratively set prices are based on skewed data from larger RPS contracts that are over two years old, and do not represent a true cost of energy since they do not consider Transmission Access Charges or a value of resilience. Instead, ReMAT must be temporarily applied with the fewest possible changes to allow projects waiting in the interconnection queue to begin procuring, and then an ideal successor tariff must be created based on the Feed-In Tariff the Clean Coalition designed for the City of San Diego.

CEC: Solar+storage is superior to diesel generators for backup power at Microsoft data center | 21 July 2020
In this filing, the Clean Coalition urges the California Energy Commission (CEC) to consider solar+storage primarily, along with other suitable renewable alternatives, to determine how many of the 40 (3 MW) diesel generators could be replaced in Microsoft’s proposed data center project in San Jose, CA. The current proposal does not consider anything beyond diesel generators, which, if installed, will pollute a low-income and disadvantaged community in San Jose.

FERC: Urgency in addressing Transmission Access Charges when valuing DER | 15 June 2020
This filing represents the Clean Coalition’s comments urging the Federal Energy Regulatory Commission (FERC) to deny a petition that constitutes federal overreach into an issue that must be left to the states. The petition would allow FERC to regulate any excess NEM energy sold to the utility as soon as it leaves the customer meter, which is a mistake considering that almost zero excess energy ever reaches the wholesale market (or uses the transmission system). We submit that approving the petition would further depress the true value of DER, which is why FERC would be better off denying the petition and considering addressing Transmission Access Charges.

CPUC: Intervenor compensation eligibility | 12 June 2020
This filing represents the Clean Coalition’s comments opposing a CPUC Proposed Decision that would find us ineligible for intervenor compensation for participation in this CPUC proceeding, with implications for other proceedings. A finding was made in R.15-02-020 that mischaracterized the work of the Clean Coalition as a market participant rather than an environmental ratepayer advocate, negatively impacting eligibility for compensation for substantial contributions made in CPUC decisions. We argue that the finding erred both legally and factually.

CARB: Advanced Clean Truck regulation support letter | 28 May 2020
In this letter to the California Air Resources Board (CARB), the Clean Coalition applauds the Board for considering a more stringent Advanced Clean Truck rule and urges them to affirm the new rule, with the modification that it be reconsidered in three years (rather than five). We also argue that the rule should apply to all medium and heavy class trucks and request that the definition of “large fleet” be changed from 100 or greater to anything over 50.

CPUC: Microgrids and strategies for valuing resilience – reply comments | 26 May 2020
This filing represents the Clean Coalition’s support of requests from other parties, primarily related to issues surrounding utility transparency with the CPUC and other stakeholders, for assurances that fossil fuel generation is temporary and will be transitioned into renewable resources, including proposals to expedite microgrid interconnection.

CPUC: Microgrids and strategies for valuing resilience | 19 May 2020
This filing represents the Clean Coalition’s argument that PG&E (or any other IOU) installing natural gas generation for resilience should be required to submit a plan detailing a transition to DER and solar+storage microgrids within five years. We promote proposals to expedite interconnection, although we lambast the CPUC’s lack of interest in smart metering. The Clean Coalition also applauds decisions to remove energy storage sizing limits, though we request that the CPUC requires islanding — either in this track or in track 2. Our comments also focus on ensuring that this Proposed Decision promotes progress, not more of the business-as-usual approach by utilities and policymakers; to that end, we request that the Proposed Decision is modified to ensure that the CPUC considers key details (like the value of resilience) and promotes transparency in information sharing between IOUs and key stakeholders.

CPUC: Resuming ReMAT under PURPA | 28 April 2020
This filing represents comments filed by joint parties including the Clean Coalition, public agencies, and private energy firms supporting the proposed expansion of PURPA small renewable energy contract terms and necessary contract lengths to support financing. We additionally emphasize the importance of avoiding a delay in the adoption of PURPA terms in order to allow the associated Renewable Market Adjusting Tariff (ReMAT) procurement program to resume.

CPUC: DER Avoided Cost Calculator and transmission – reply comments | 7 April 2020
This filing represents the Clean Coalition’s reply comments on the proposed decision modifying the DER Avoided Cost Calculator. We reinforce the need for correction of the transmission value of DER in the calculator used across CPUC proceedings. We note agreement from multiple parties in opening comments for both the immediate adoption of interim methodologies and a full refinement before the end of 2020. We also rebut assertions that DER does not mitigate all drivers of transmission investment, detailing examples and expanding upon our opening comments.

CPUC: DER Avoided Cost Calculator and transmission | 2 April 2020
This filing represents the Clean Coalition’s comments on the proposed decision modifying the DER Avoided Cost Calculator. We largely support the proposal with the exception of the transmission valuation. Expressing the true value of transmission costs that can be avoided through the use of DER and microgrids is a critical component of the cost-effectiveness of any sort of DER project, program, or policy. We provide examples of billions of dollars of actual DER-driven avoided annual transmission costs, and argue that the Avoided Cost Calculator must reflect these savings.

CPUC: Proper valuation of DER | 26 February 2020
This filing represents the Clean Coalition’s comments on the CPUC’s Decision Adopting Staff Proposal on Avoided Costs and Locational Granularity of Transmission and Distribution Deferral Values, in which we dispute staff conclusions of negligible value of DER and call for a schedule for consistent valuation across utilities based on the record of factual data.

CPUC: Proving microgrid resilience benefits – reply comments |6 February 2020
This filing represents the Clean Coalition’s reply to the staff and investor-owned utility (IOU) proposals on short-term resilience strategies. The Clean Coalition’s comments prioritize holding the IOUs accountable by tracking the total cost of fossil-fuel generation (proving that renewables-driven microgrids are a more effective solution), sharing information with local agencies, annual verification reports, and pushing for a more widespread deployment of smart meters with islanding capabilities across IOU service territory.

CPUC: Proving microgrid resilience benefits | 30 January 2020
This filing represents the Clean Coalition’s reply to the CPUC administrative law judge’s questions about the staff and investor-owned utility proposals for microgrid resilience strategies. Our comments lambast the potential use of fossil-fuel generation near substations and prioritize DER generation, along with an increase in grid isolation switches, and we illustrate effective use of data sources to map priority microgrid siting. The Southern California Edison proposal includes a portion in Montecito, so our comments use the Montecito Community Microgrid Initiative and greater Goleta Load Pocket area to demonstrate the resilience that a true Community Microgrid can bring and a few of the policies inhibiting them from being built.

CPUC: Improving construction timelines and more under Rule 21 – reply comments | 27 January 2020
This filing represents the Clean Coalition’s reply comments on the CPUC’s administrative law judge’s questions following the submission of proposals for improving interconnection in the Rule 21 Working Group 3 Final Report and workshop presentations. In reply, the Clean Coalition focuses on correction of Cost of Ownership grid upgrade cost allocations improperly burdening new distributed renewables, as well as other issues.

CPUC: Improving construction timelines and more under Rule 21 | 13 January 2020
This filing represents the CPUC’s administrative law judge’s questions following the submission of proposals for improving interconnection in the Rule 21 Working Group 3 Final Report and workshop presentations. The Clean Coalition focuses on those questions related to our proposals regarding use of non-utility contractors to improve construction timelines and correction of Cost of Ownership grid upgrade cost allocations improperly burdening new distributed renewables, as well as other issues.

2019

CPUC: The Avoided Cost Calculator and avoided transmission value | December 30, 2019
This filing represents the Clean Coalition’s support for the staff proposal (with the exception of the transmission valuation) that the Avoided Cost Calculator (ACC) needs to adopt an avoided transmission value pending future refinement in the DRP proceeding. Expressing the true value of transmission costs that can be avoided through the use of DER is a critical component of the cost-effectiveness of any sort of DER project, program, or policy. We provide examples of billions of dollars of actual DER driven avoided annual transmission costs, and argue that the ACC must reflect these savings.

CPUC: Streamlining interconnection in 2019 | December 24, 2019
The Clean Coalition submitted comments on the policy mechanisms needed to streamline interconnection via the Clean Coalition’s WDG Streamlined Interconnection Pilot and an Interconnection Roadmap for Automation written by Sahm White and Tam Hunt of the Green Power Institute. The comments mentioned interconnection difficulties experienced during the VGES interconnection process as well as the interconnection case study currently being prepared. The comments end with a short reply on the other proposals presented at the forum

CEC: Climate adaptation and the Clean Coalition’s work | November 27, 2019
This filing represents the Clean Coalition’s comments on the CEC’s Integrated Energy Policy Report Workshop on Climate Adaptation. The Clean Coalition appreciates the focus on supporting microgrids with distributed energy resources (DER) for critical facilities and believes it is crucial for the IEPR to consider measures needed to proliferate Community Microgrids in California. This proliferation can be ensured by reforming the way Transmission Access Charges (TAC) are assessed, divesting the IOUs of their transmission assets, streamlining interconnection for wholesale distributed generation (WDG), establishing effective procurement methods like a market-responsive Feed-In Tariff (FIT), and standardizing a Value of Resilience for all electric loads (VOR123).

CPUC: Extended Day Ahead Markets and Transmission Access Charges | November 22, 2019
This filing represents the Clean Coalition’s comments on the issue paper in the CAISO stakeholder process on Extended Day Ahead Markets (EDAM). Our recommendations focused on reforming Transmission Access Charges (TAC) so they are measured at transmission distribution stations rather than at individual customer meters. Implementing this solution in coordination with the CPUC would promote the deployment of Distributed Energy Resources (DER) for EDAM, saving 3 cents per kilowatt on local clean energy projects and reducing the need for transmission infrastructure expansion.

CPUC: Valuing resilience with Community Microgrids – reply comments | November 4, 2019
This filing represents the Clean Coalition’s reply comments on the opening comments made by 36 parties about the Preliminary Scoping Document for Rulemaking 19-09-009. The Clean Coalition called for a focus on Community Microgrids and focused on comments by parties explaining that they are an important alternative to expanding the transmission system for the sake of grid hardening and provide both baseload and backup power for a community. We recommended that based on the consensus about the importance of Community Microgrids as a resilient solution, an essential part of this proceeding must be to create a standard value of resilience. These comments were made regarding California Microgrid Bill SB 1339.

CPUC: Valuing resilience with Community Microgrids | October 21, 2019
This filing represents the Clean Coalition’s opening comments advising the CPUC to focus the upcoming proceeding on Community Microgrids, with a focus on the Goleta Load Pocket as the ideal location for a pilot program. We recommended the CPUC properly value resilience by using VOR123 as well as implementing a Feed-In Tariff mechanism, with Market Responsive Pricing and a Dispatchability Adder (DECS), to streamline the procurement of renewable resources for Community Microgrids. These comments were made on the Order Instituting Rulemaking (OIR) Regarding Microgrids Pursuant to SB 1339.

CPUC: Reopening ReMAT and supporting pending projects | August 13, 2019
This filing represents the Clean Coalition’s joint party letter in response to the Appleate Court ruling upholding a stay on the CPUC’s renewable energy market adjusting tariff (ReMAT) due to the failure to also offer PURPA compliant alternatives. We offered legal analysis to make it clear that there is no actual injunction against ReMAT and that pending projects should be allowed to contract without further delay following approval of the draft Proposed Decision.

CPUC: ICA maps and groundbreaking transparency into the California’s energy distribution system | August 1, 2019
This filing represents the Clean Coalition’s opening comments on refinements to the newly implemented Interconnection Capacity Assessment (ICA) maps and data access to improve their user functionality and continue development of this groundbreaking transparency into the California’s energy distribution system. While continuing to support the long term recommendations of the ICA working group in which we were a leading participant, we drew attention to issues with the initial statewide implementation. We also further promoted the use cases for the ICA beyond the interconnection process itself, addressing its important role in planning appropriately targeted local distribution investment and assessing the impact of policy options.

CPUC: Urging reinstatement of ReMAT | August 1, 2019
Ths filing represents a joint party letter in response to the Appleate Court ruling upholding a stay on the CPUC’s renewable energy market adjusting tariff (ReMAT) due to the failure to also offer PURPA compliant alternatives. The Clean Coalition urged the CPUC to promptly approve the PURPA options in the December 2018 settlement proposal and re-instate the ReMAT program without delay.

CPUC: Comments on Interconnection Practices and Distribution Resources Planning maps | July 17, 2019
This filing represents the Clean Coalition and Green Power Institute’s joint informal comments offering written feedback following the initial stakeholder meeting on publication of ongoing deployment data. The Clean Coalition strongly supports the framework currently utilized for CSI and NEM data with the addition of greater granularity by size, technology and location, and alignment with related Distribution Resources Planning maps (ICA, LNBA and GNA).

CPUC: Comments on the Interconnection Practices Evaluation Research Plan | July 10, 2019
This filing represents the Clean Coalition and Green Power Institute’s joint comments offering written feedback following the initial stakeholder meeting on the proposed Interconnection Practices Evaluation Research Plan. The Clean Coalition strongly supports the initiative, but calls for more extensive research questions, data development, and outreach covering all applications of 100 kW and above, and analysis of results prior to initial development of recommendations.

CPUC: Methodologies for calculating avoided distribution and transmission costs attributable to DER growth | June 21, 2019
This filing represents the Clean Coalition’s brief comments on the white paper prepared by the CPUC’s Energy Division related to methodologies for calculating avoided distribution and transmission costs attributable to DER growth in the Avoided Cost Calculator, Locational Net Benefits Assessment, and associated proceedings. While we support the distribution level methods, the estimated results at the transmission level are far below actual reported. We submitted evidence and cited examples of actual transmission savings and methodological factors for further consideration.

CPUC: Procuring energy storage with a FIT approach and market responsive pricing| March 9, 2019
This filing represents the Clean Coalition’s proposal to amend the Proposed Decision modifying the applications by SDG&E, PG&E, and SCE regarding procurement of new energy storage in compliance with AB 2868. We broadly support the PD but oppose the use of an RFO bidding procurement process and recommend use of a FIT approach with Market Responsive Pricing. This avoids the costly barriers to participation inherent in RFO bidding, which is inappropriate for distributed resource procurement. A FIT will result in greater market participation and lower costs for ratepayers.

CPUC: Appropriate allocation in interconnection | February 22, 2019
This filing represents the Clean Coalition’s review and reply to opening responses to the CPUC ALJ’s questions regarding the Final Report of Working Group 2 on Interconnection Streamlining. Our brief comments focus on the issues raised regarding assessment of costs and benefits of investment in improvements in interconnection processes and appropriate allocation.

CPUC: Intervenor compensation arguments | February 21, 2019
This filing represents the Clean Coalition’s comments opposing CPUC Commisioner Randolf’s Alternate Proposed Decision which would find us ineligible for intervenor compensation for participation in this CPUC proceeding, with implications for other proceedings. A finding was made in R.15-02-020 that mischaracterized the work of the Clean Coalition as a market participant rather than an environmental ratepayer advocate, negatively impacting eligibility for compensation for substantial contributions made in Commission Decisions. We argue that the finding errored both legally and factually and the Commission adopt the earlier Proposed Decision of Administrative Law Judge Hymes awarding compensation. The ex parte letter to the CPUC is located here.

CPUC: Reopening the ReMAT program in California | February 20, 2019
This filing represents a joint letter to CPUC commissioners urging the CPUC to proceed with adopting the PURPA Proposed Decision to enable the ReMAT program to be reopened without delay and proceed with approved procurement of the remaining 200 MW of capacity.

CPUC: Threats against the Green Tariff Shared Renewables program | February 8, 2019
This filing represents the Clean Coalition’s response related to Southern California Edison’s application to terminate the Green Tariff Shared Renewables program and replace it with five proposed Green Energy Programs. We argue that a Feed-in Tariff can be implemented consistent with Senate Bill 43 and is a better alternative.

CPUC: Final report on interconnection streamlining | February 1, 2019
This filing represents the Clean Coalition’s responses to the CPUC administrative law judge’s questions regarding the Final Report of Working Group 2 on interconnection streamlining, with a major focus on integration of newly available ICA hosting capacity results into the interconnection application review process and tariff, and other process and automation improvements.

CPUC: Opposing restricted access to PV RAM maps with IREC, SEIA, CSSA, and Vote Solar | January 9, 2019
This filing represents joint comments with the Interstate Renewable Energy Council (IREC), Solar Energy Industries Association (SEIA), California Solar & Storage Association (CSSA), California Community Choice Association, and Vote Solar to oppose the investor-owned utility Petition for Modification to restrict access to exising PV Renewable Auction Mechanism (RAM) interconnection maps and application of a non-disclosure agreement. We argue that utilities have not shown cause and note established compliance with prior rulings requiring publication, including the recent Ruling (R.14-08-013 Dec. 17, 2018) denying identical utility action related to the new Interconnection Capacity Analysis hosting capacity maps.

CPUC: Joint letter on Resource Adequacy Proposed Decision | January 3, 2019
This filing represents a joint letter to California Public Utilities Commission (CPUC) Commissioners urging the rejection the Proposed Decision issued November 21, 2018 regarding Resource Adequacy (RA) which puts investor-owned utilities (IOUs) in an exclusive central buyer role for local RA and allows IOUs to recover RA costs through non-bypassable charges. Most parties agree that a “residual” rather than “full” central buyer model is the better choice.

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.