Consistency With Minimum Quantity Decision. In D.00-00-000, the Commission determined that in order to count energy deliveries from short-term contracts with existing facilities toward RPS goals, RPS-obligated load- serving entities must contract for deliveries equal to at least 0.25 percent of their prior year’s retail sales through long-term contracts or through short-term contracts with new facilities. The PPA is a long-term contract executed in 2011 and thus counts towards PG&E’s procurement obligation under D.00-00-000. PG&E expects that, in 2011, it will be in compliance with the minimum quantity set for in D.00-00-000 and will contribute to meeting requirements in the 2011-2013 compliance period and beyond, in accordance with SBX1 2.
Consistency With Minimum Quantity Decision. In D.00-00-000, the Commission determined that in order to count energy deliveries from short-term contracts with existing facilities toward RPS goals, RPS-obligated load- serving entities must contract for deliveries equal to at least 0.25 percent of their prior year’s retail sales through long-term contracts or through short-term contracts with new facilities. The Commission issued D.00-00-000 to implement the requirements of then- existing Public Utilities Code Section 399.14(b)20, which created incentives for entering into particular types of procurement contracts.21 In order to implement these incentives, the Commission required each Load Serving Entity (“LSE”) seeking approval of a contract to procure energy to indicate which category the submitted contract falls. Under this decision, the Commission measures contracted-for energy. The minimum quantity decision is neither applicable to REC-only contracts nor necessary. REC-only contracts do not procure energy deliveries. Therefore, measurements of contracted-for energy are inapplicable. Further, the minimum quantity requirements are unnecessary to act as a “gatekeeper” for REC-only contracts. Instead, as discussed above in Section E, the Commission and the Legislature have promulgated specific restrictions applicable to REC-only transactions, which this PSA has satisfied. Even if the Commission were to apply this requirement to RECs-only contracts, PG&E expects to be in compliance with minimum requirements for deliveries from long-term contracts in 2011.
Consistency With Minimum Quantity Decision. In D.00-00-000, the Commission determined that in order to count energy deliveries from short-term contracts with existing facilities toward RPS goals, RPS-obligated load- serving entities must contract for deliveries equal to at least 0.25 percent of their prior year’s retail sales through long-term contracts or through short-term contracts with new facilities. The Commission issued D.00-00-000 to implement the requirements of then- existing Public Utilities Code Section 399.14(b)23, which created incentives for entering into particular types of procurement contracts.24 In order to implement these incentives, the Commission required each Load Serving Entity (“LSE”) seeking approval of a contract to procure energy to indicate which category the submitted contract falls. Under this decision, the Commission measures contracted-for energy. The minimum quantity decision is neither applicable to REC-only contracts nor necessary. REC-only contracts do not procure energy deliveries. Therefore, measurements of contracted-for energy are inapplicable. Further, the minimum quantity 19 See OIR, Docket No. R.00-00-000, Att. A, p. 1 (May 5, 2011). 20 Pub. Util. Code § 399.12(f)(2).
Consistency With Minimum Quantity Decision. The PPA is a long-term contract with a new facility. All of the RPS contracts that PG&E has signed this year are with new facilities and/or are long-term.
