CONSISTENCY WITH COMMISSION DECISIONS. A. Consistency With PG&E’s Adopted RPS Procurement Plan PG&E’s 2009 Renewable Procurement Plan (“2009 Plan”) was conditionally approved in D.00-00-000 on June 4, 2009. As required by statute, the 2009 Plan included an assessment of supply and demand to determine the optimal mix of renewable generation resources, consideration of compliance flexibility mechanisms established by the Commission, and a bid solicitation setting forth the need for renewable generation of various operational characteristics.8 The PPA is also consistent with PG&E’s 2009 Plan because it adhered to PG&E’s Solicitation Protocol, which is the primary component of the 2009 Plan. The goal of PG&E’s 2009 Plan is to procure approximately one to two percent of its retail sales volume, or between 800 GWh and 1,600 GWh, per year. With expected RPS- eligible energy deliveries, on average, of approximately 303 GWh per year, the PPA meets the criteria for the renewables procurement contained in the 2009 Plan. Projects capable of providing actual deliveries in the near-term are especially valuable to PG&E to improve the likelihood of RPS compliance during the first compliance period (2011- 2013). Additionally, the PPA will contribute to PG&E’s longer-term RPS goals. The Project also meets the criteria for the renewables procurement contained in PG&E’s 2011 RPS Plan. The 2011 RPS Plan was conditionally approved in D.00-00-000 on April 14, 2011. PG&E submitted a final version of the 2011 RPS Plan on May 4, 2011. The goal of PG&E’s 2011 RPS Plan is to procure approximately one to two percent of PG&E’s annual retail sales volume, or 800 to 1,600 GWh per year. With expected RPS- eligible energy deliveries of 303 GWh per year for a term of 25 years commencing in 2012, the output from the Project will contribute a significant quantity of renewables procurement towards PG&E’s RPS goals consistent with PG&E’s 2011 RPS Plan. Advice 3884-E - 7 - August 4, 2011
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CONSISTENCY WITH COMMISSION DECISIONS. A. Consistency With with PG&E’s Adopted RPS Procurement Plan PG&E’s 2009 Renewable Procurement Plan 2007 renewable procurement plan (“2009 2007 Plan”) was conditionally approved in D.00-00-000 on June 4, 2009000. As required by statute, the 2009 2007 Plan included includes an assessment of supply and demand to determine the optimal mix of renewable generation resources, consideration of compliance flexibility mechanisms established by the Commission, and a bid solicitation setting forth the need for renewable generation of various operational characteristics.8 The PPA is also consistent with PG&E’s 2009 Plan because it adhered to PG&E’s Solicitation Protocol, which is the primary component of the 2009 Plan. characteristics.3 The goal of PG&E’s 2009 2007 Plan is was to procure approximately one to two percent of its retail sales volume, or between 800 750 GWh and 1,600 GWh, 1,500 GWh per year, with delivery terms of 10, 15 or 20 years. With expected RPS- RPS-eligible energy deliveries, on average, deliveries of approximately 303 145 GWh average per yearyear for a term of 20 years beginning March 31, 2012, the PPA meets the criteria for the renewables procurement contained in the 2009 2007 Plan. Projects capable of providing actual deliveries in the near-term are especially valuable to PG&E to improve the likelihood of RPS compliance during the first compliance period (2011- 2013). Additionally, the The PPA will contribute to PG&E’s longer-term 2010 RPS goals. The Project also meets the criteria for the renewables procurement contained in PG&E’s 2011 RPS Plan. The 2011 RPS Plan was conditionally approved in D.00-00-000 on April 14target, 2011. PG&E submitted a final version of the 2011 RPS Plan on May 4with flexible compliance, 2011. The goal of PG&E’s 2011 RPS Plan is and to procure approximately one to two percent of PG&E’s annual retail sales volume, or 800 to 1,600 GWh per year. With expected RPS- eligible energy deliveries of 303 GWh per year for a term of 25 years commencing in 2012, the output from the Project will contribute a significant quantity of renewables procurement towards PG&E’s RPS goals in the years beyond 2010. The proposed PPA is also consistent with PG&E’s 2011 RPS 2007 Plan because it was solicited, negotiated and executed through PG&E’s adherence to its Solicitation Protocol, which is the primary component of the 2007 Plan. PG&E generally followed the RPS Solicitation schedule set forth in its Solicitation Protocol, but ultimately, the schedule for concluding negotiations was necessarily extended. The resulting 2007 Solicitation schedule is shown below: 3 Pub. Util. Code § 399.14(a)(3). Date Event March 12, 2007 PG&E issues Solicitation March 23, 2007 Deadline for Participant to submit non- binding Notice of Intent to Bid and reservation for Bidders Conference April 3, 2007 Bidders Conference May 31, 2007 Deadline for Participants to submit Offer(s) July 16, 2007 PG&E selects Shortlist of Offers and consults with Procurement Review Group (“PRG”) By December 31, 2007 PG&E and Participants negotiate and execute Agreements subject to Regulatory Approval; PG&E submits Agreements for Regulatory Approval June 12, 2008 PG&E submits first and second power purchase agreements, San Xxxxxxx SOLAR 1 LLC and San Xxxxxxx SOLAR 2 LLC, for Commission approval August 14, 2008 PG&E submits third and fourth power purchase agreements, Topaz Solar Farms LLC and High Plains Ranch II, LLC, for Commission approval June 25, 2009 PG&E submits fifth power purchase agreement, Alpine Suntower, LLC, for Commission approval September 21, 2009 PG&E submits its sixth power purchase agreement, Mt. Poso Cogeneration Company, LLC, for Commission approval October 26, 2009 PG&E submits its seventh power purchase agreement, Genesis Solar, LLC, for Commission approval October 27, 2009 PG&E submits eighth power purchase agreement, Mojave Solar, for Commission approval On May 11, 2010 PG&E concurrently withdraws Advice 3884Letter 3481-E - 7 - August 4, 2011and submits the current Alpine Suntower PPA for Commission approval
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CONSISTENCY WITH COMMISSION DECISIONS. A. Consistency With PG&E’s Adopted RPS Procurement Plan The Fourth Amendment will benefit PG&E’s 2009 customers by: (1) allowing an existing QF resource that provides RPS-eligible energy to continue operations and deliver renewable energy at a competitive price; and (2) modifying the PPA’s performance obligations so that production from the Facility will be more in line with historical delivery levels and provide deliveries on a year-round basis. Senate Bill 2 in the First Extraordinary Session of the 2011 Legislative Session (“SB 2 1X”) requires load-serving entities (“LSEs”) to gradually increase procurement of renewable resources until such deliveries meet 33 percent of their retail sales. The statute creates a compliance structure that includes both enforceable compliance period targets and unenforceable reasonable progress targets for individual years through 2020. The reasonable progress targets will be used to establish the total enforceable quantities of renewable deliveries that each LSE will need to procure by the end of each compliance period. For instance, while SB 2 1X requires that LSEs procure an average of 20% of retail sales from renewable resources for the first compliance period of January 1, 2011, to December 31, 2013,3 the Commission has yet to define the reasonable progress targets for the second and third compliance periods (2014-2016 and 2017-2020, respectively). Once the Commission has established the reasonable progress targets for these later compliance periods, LSEs will be able to calculate the percentages of their total sales for each respective period that represents the enforceable compliance period targets.4 PG&E’s 2011 Renewable Energy Procurement Plan (“2009 2011 RPS Plan”) was conditionally approved in D.00-00-000 on June 4, 2009. As required by statute, the 2009 Plan included an assessment of supply and demand to determine the optimal mix of renewable generation resources, consideration of compliance flexibility mechanisms established by the Commission, and a bid solicitation setting forth the need for renewable generation of various operational characteristics.8 The PPA is also consistent with PG&E’s 2009 Plan because it adhered to PG&E’s Solicitation Protocol, which is the primary component of the 2009 Plan. The goal of PG&E’s 2009 Plan is to procure approximately one to two percent of its retail sales volume, or between 800 GWh and 1,600 GWh, per year. With expected RPS- eligible energy deliveries, on average, of approximately 303 GWh per year, the PPA meets the criteria for the renewables procurement contained in the 2009 Plan. Projects capable of providing actual deliveries in the near-term are especially valuable to PG&E to improve the likelihood of RPS compliance during the first compliance period (2011- 2013). Additionally, the PPA will contribute to PG&E’s longer-term RPS goals. The Project also meets the criteria for the renewables procurement contained in PG&E’s 2011 RPS Plan. The 2011 RPS Plan was conditionally approved in D.00-00-000 on April 1420, 2011. PG&E submitted a final version of In the 2011 RPS Plan on May 4Plan, 2011PG&E indicated that it was “pursuing both short- and long-term contracts to meet [the] statutory goals” set forth in SB 2 1X.5 The amended PPA will help PG&E to maintain its baseline RPS portfolio, which provides a foundation from which PG&E can make progress toward compliance with the 33 percent RPS program. The goal of PG&E’s 2011 RPS Plan is to procure approximately one to two percent of PG&E’s annual retail sales volume, or 800 to 1,600 GWh per year. With expected RPS- eligible energy deliveries of 303 GWh per year for a term of 25 years commencing Fourth Amendment therefore meets the needs defined in 2012, the output from the Project will contribute a significant quantity of renewables procurement towards PG&E’s RPS goals consistent with PG&E’s 2011 RPS Plan. Advice 3884-E - 7 - August 4, 2011.
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CONSISTENCY WITH COMMISSION DECISIONS. A. Consistency With PG&E’s Adopted RPS Procurement Plan PG&E’s 2009 Renewable Procurement Plan (“2009 Plan”) was conditionally approved in D.00-00-000 on June 4, 2009. As required by statute, the 2009 Plan included an assessment of supply and demand to determine the optimal mix of renewable generation resources, consideration of compliance flexibility mechanisms established by the Commission, and a bid solicitation setting forth the need for renewable generation of various operational characteristics.8 The PPA is also consistent with PG&E’s 2009 Plan because it adhered to PG&E’s Solicitation Protocol, which is the primary component of the 2009 Plan. The goal of PG&E’s 2009 Plan is to procure approximately one to two percent of its retail sales volume, or between 800 GWh and 1,600 GWh, per year. With expected RPS- eligible energy deliveries, on average, of approximately 303 GWh per year, the PPA meets the criteria for the renewables procurement contained in the 2009 Plan. Projects capable of providing actual deliveries in the near-term are especially valuable to PG&E to improve the likelihood of RPS compliance during the first compliance period (2011- 2013). Additionally, the PPA will contribute to PG&E’s longer-term RPS goals. The Project also meets the criteria for the renewables procurement contained in PG&E’s 2011 RPS Plan. The 2011 RPS Plan was conditionally approved in D.00-00-000 on April 14, 2011. PG&E submitted a final version of the 2011 RPS Plan on May 4, 2011. The goal of PG&E’s 2011 RPS Plan is to procure approximately one to two percent of PG&E’s annual retail sales volume, or 800 to 1,600 GWh per year. With expected RPS- eligible energy deliveries of 303 GWh per year for a term of 25 years commencing in 2012, the output from the Project will contribute a significant quantity of renewables procurement towards PG&E’s RPS goals consistent with PG&E’s 2011 RPS Plan. Advice 3884-E - 7 - August 4, 2011.
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CONSISTENCY WITH COMMISSION DECISIONS. A. Consistency With PG&E’s Adopted RPS Procurement Plan The Second Amendment will benefit PG&E’s 2009 customers by: (1) allowing an existing QF resource that provides RPS-eligible energy to continue operations and deliver renewable energy at a competitive price; and (2) modifying the PPA’s performance obligations so that production from the Facility will be more reliable and provide deliveries on a year- round basis. Senate Bill 2 in the First Extraordinary Session of the 2011 Legislative Session (“SB 2 1X”) requires load-serving entities (“LSEs”) to gradually increase procurement of renewable resources until such deliveries meet 33% of their retail sales. The statute creates a compliance structure that includes both enforceable compliance period targets and unenforceable reasonable progress targets for individual years through 2020. The reasonable progress targets will be used to establish the total enforceable quantities of renewable deliveries that each LSE will need to procure by the end of each compliance period. For instance, while SB 2 1X requires that LSEs procure an average of 20% of retail sales from renewable resources for the first compliance period of January 1, 2011, to December 31, 2013,7 the Commission has yet to define the reasonable progress targets for the second and third compliance periods (2014-2016 and 2017-2020, respectively). Once the Commission has established the reasonable progress targets for these later compliance periods, LSEs will be able to calculate the percentages of their total sales for each respective period that represents the enforceable compliance period targets.8 PG&E’s 2011 Renewable Energy Procurement Plan (“2009 2011 RPS Plan”) was conditionally approved in D.00-00-000 on June 4, 2009. As required by statute, the 2009 Plan included an assessment of supply and demand to determine the optimal mix of renewable generation resources, consideration of compliance flexibility mechanisms established by the Commission, and a bid solicitation setting forth the need for renewable generation of various operational characteristics.8 The PPA is also consistent with PG&E’s 2009 Plan because it adhered to PG&E’s Solicitation Protocol, which is the primary component of the 2009 Plan. The goal of PG&E’s 2009 Plan is to procure approximately one to two percent of its retail sales volume, or between 800 GWh and 1,600 GWh, per year. With expected RPS- eligible energy deliveries, on average, of approximately 303 GWh per year, the PPA meets the criteria for the renewables procurement contained in the 2009 Plan. Projects capable of providing actual deliveries in the near-term are especially valuable to PG&E to improve the likelihood of RPS compliance during the first compliance period (2011- 2013). Additionally, the PPA will contribute to PG&E’s longer-term RPS goals. The Project also meets the criteria for the renewables procurement contained in PG&E’s 2011 RPS Plan. The 2011 RPS Plan was conditionally approved in D.00-00-000 on April 1420, 2011. PG&E submitted a final version of In the 2011 RPS Plan on May 4Plan, 2011PG&E indicated that it was “pursuing both short- and long-term contracts to meet [the] statutory goals” set forth in SB 2 1X.9 The Second Amendment will help PG&E to maintain its baseline RPS portfolio, which provides a foundation from which PG&E can make progress toward compliance with the 33% RPS program. The goal of Second Amendment therefore meets the needs defined in the 2011 RPS Plan. PG&E’s 2011 RPS Plan is Solicitation Protocol requests participants to procure approximately one to two percent of PG&E’s annual retail sales volumedescribe how their projects improve environmental quality, or 800 to 1,600 GWh per year. With expected RPS- eligible energy deliveries of 303 GWh per year for a term of 25 years commencing in 2012, the output from the Project will contribute a significant quantity of renewables procurement towards PG&E’s RPS goals consistent with PG&E’s 2011 RPS Plan. Advice 3884-E - 7 - August 4, 2011stimulate sustainable economic development,
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