Dive Brief:

• California regulators are considering eliminating "alternative plans" that included simplified filing requirements for smaller utility Integrated Resource Plans (IRPs), and instead may require all load serving entities (LSEs) to file a standard plan in an effort to shore up the state's resource planning process.
• The California Public Utilities Commission will take comments until Oct. 14 on a staff proposal to strengthen filing requirements for individual LSEs required to file IRPs by May 2020.
• Southern California Edison (SCE) says it supports efforts to strengthen the IRP process, but cautioned that eliminating alternative plans would require regulators to adjust greenhouse gas (GHG) planning targets and demand forecasts.

Dive Insight:

The rise of LSEs in California, driven in particular by community choice aggregation programs, has the state moving quickly to ensure the grid stays reliable while meeting environmental mandates. But SCE said the answer is more complex than simply eliminating alternative plans.

Stronger planning standards will help the CPUC staff evaluate and compare each LSE’s plan, and ultimately help integrate the plans into a Preferred System Plan that will underpin electricity generation procurement, SCE spokesperson Robert Laffoon-Villegas told Utility Dive.

The reference system plan was used by LSEs to file long-term plans, which willbe used to develop a Preferred System Plan to drive procurement and program activity.

"As long as the commission’s planning standards and Reference System Plan adequately reflect the electric sector portfolio needed to affordably maintain system reliability and meet California’s statewide GHG goals, eliminating the alternative plan option and requiring conformance with the Reference System Plan is sensible," Laffoon-Villegas said in an email.

But he added that eliminating the possibility to file alternative plans means the commission must require planning targets and demand forecasts that account for economy-wide decarbonization measures like sufficient amounts of electric vehicles and energy efficiency to meet California's emissions goals.

"It’s likely the Commission’s final planning standards for this IRP cycle will not" include more comprehensive, economy-wide targets, Laffoon-Villegas said.

The utility believes the 2019-2020 Reference System Plan and planning standards should reflect "a more stringent 2030 electric sector GHG emissions planning target," he said.

CPUC staff previously modeled three core policy cases to understand how GHG planning targets could impact resource build-out requirements, costs and risk. The commission adopted a reference system plan goal of 42 million metric tons (MMT) for the electric sector in 2030 as part of the 2017-18 IRP process.

According to Laffoon-Villegas, a 30 MMT target represents an 80% carbon-free grid, higher levels of electrification, "and higher energy efficiency levels in line with state goals to effectively facilitate achievement of the state's 2030 GHG emissions reduction goals."

Staff's proposed changes would require all LSEs in the California ISO Balancing Authority Area to file Standard Plans "regardless of size, therefore eliminating the alternative plan." 

"Requesting contractual information from all LSEs will improve the aggregation process, especially due to the proliferation of Community Choice Aggregators... which in aggregate may represent a significant share of load," staff said.

The changes would also require all LSEs to only file conforming portfolios, "therefore eliminating the Alternative Portfolio option: LSEs may only file plans that conform with 2019 Reference System Plan inputs and assumptions ... assigned GHG emissions benchmark and other requirements."

LSEs have been allowed to file resource portfolios that were developed from additional scenarios from the Reference System Plan and can assume that other LSEs do not procure in a manner consistent with the Reference System Plan.

Pacific Gas & Electric, San Diego Gas & Electric and Cal CCA declined to comment on the proposed changes.