Clean Energy Alliance: An Introduction to Integrated
Resource Planning (IRP)
Tim Lindl – Keyes & Fox LLP
February 29, 2024
IRP Overview
● Senate Bill 350 (2015) established modern IRP proceedings. ○ IRPs operate on a roughly two-year cycle.
○ The current proceeding is at the tail end of that cycle. ● The goal of IRP: Determining how CA should structure its energy portfolio to meet the state’s clean energy goals, while ensuring reliability and affordability.
2 IRP Legal Framework
● The requirements and scope of IRP are rooted in statute. ● Section 454.51(a) requires that the Commission:
○ “Identify a diverse and balanced portfolio of resources needed to ensure a reliable electricity supply that provides optimal integration of renewable energy and resource diversity in a cost-effective manner.”
● Section 454.52 requires that the Commission order each LSE to file integrated resource plans:
○ Meeting CA’s emissions reduction targets.
○ Procure at least 60 percent eligible renewable energy resources by 12/31/30. ○ Fulfill the “obligation to serve its customers at just and reasonable rates.” ○ “Minimize impacts on ratepayers’ bills.”
○ Ensure reliability.
○ Address transmission and distribution related issues. 3 IRP Proceedings Are Critical to LSEs
● LSEs must formally plan for their procurement on rolling, multi-year timelines.
○ The Commission then approves or disapproves LSE submissions. ○ Decision is based on whether individual plan (i) includes resources matching the LSEs reliability need, (ii) meets the LSE’s emissions limits. ○ LSEs must also include a narrative with their submission. ● IRP decisions may dictate resource “winners and losers.” 4 The Current State of Play
● In January 2024, ALJ Fitch issued a Proposed Decision adopting the latest Preferred System Portfolio.
● The Proposed Decision initially adopted an inconsistent position regarding CEA’s individual submission.
○ In certain portions, CEA’s submission was deemed adequate and the decision stated that CEA ”provided all of the required information to an adequate degree or better[.]”
○ In other portions, the Proposed Decision listed CEA’s individual submission as “Not Yet Approved or Certified.”
● D.24-02-047 corrected the discrepancy; CEA’s IRP is certified. 5 The Current State of Play
● The Decision:
○ Adopts a Preferred System Portfolio that meets a 25 MMT GHG target for the electric sector in 2035.
○ Adopts that portfolio as the base case for the Transmission Planning Process. ● The Decision picks “winners and losers.”
○ Out-of-state wind is restricted based on transmission and demand related issues. ○ Off-shore wind in some areas is increased based on anticipated transmission availability.
● Next IRP will be due after November 2024 (and perhaps later)x 6 Thank you
Contact Info:
Tim Lindl
[email protected]
510-314-8385
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