MEETING of the Energy Planning & Resources Committee
of the Clean Power Alliance of Southern California
Wednesday, October 26, 2022
12:15 p.m.
SPECIAL NOTICE: Pursuant to the Proclamation of the State of Emergency by Governor Newsom on March 4, 2020, AB 361, and enacting Resolutions, and as a response to mitigating the spread of COVID19, the Energy Planning & Resources Committee will conduct this meeting remotely.
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*While downloading the Zoom application may provide a better meeting experience, Zoom does not need to be installed on your computer to participate. After clicking the webinar link above, click “start from your browser.” Agenda Page 1
Clean Power Alliance Energy Planning & Resources Committee October 26, 2022
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PUBLIC COMMENT POLICY: The General Public Comment item is reserved for persons wishing to address the Board on any Clean Power Alliance-related matters not on today’s agenda. Public comments on matters on today’s Consent Agenda and Regular Agenda shall be heard at the time the matter is called.
Comments on items on the Consent Agenda are consolidated into one public comment period. Members of the public who wish to address the Board are requested to contact the Board Clerk, as specified above, at the beginning of the meeting but no later than immediately prior to the time an agenda item is called.
Each speaker is limited to two (2) minutes (in whole minute increments) per agenda item with a cumulative total of five 5 minutes to be allocated between the General Public Comment, the entire Consent Agenda, or individual items in the Regular Agenda. Please refer to Policy No. 8 – Public Comment for additional information.
CALL TO ORDER & ROLL CALL
GENERAL PUBLIC COMMENT
CONSENT AGENDA
1. Approve Minutes from September 28, 2022, Energy Committee Meeting
2. Receive and File September 2022 Risk Management Team Report
REGULAR AGENDA
3. Approve the 2022 Integrated Resource Plan (IRP) for Submission to the California Public Utilities Commission
4. 2022 Power Share Request for Offers
COMMITTEE MEMBER COMMENTS
ADJOURN – NEXT MEETING NOVEMBER 23, 2022
Public Records: Public records that relate to any item on the open session agenda for a Committee Meeting are available for public inspection. Those records that are distributed less than 72 hours prior to the meeting are available for public inspection at the same time they are distributed to all, or a majority of, the members of the Committee. Those documents are available for inspection online at www.cleanpoweralliance.org/agendas.
Agenda Page 2
MINUTES
REGULAR MEETING of the Energy Planning & Resources Committee of the Clean Power Alliance of Southern California
Wednesday, September 28, 2022, 12:15 p.m.
Pursuant to the Proclamation of the State of Emergency by Governor Newsom on March 4, 2020, AB 361, and enacting Resolutions, and as a response to mitigating the spread of COVID19, the Energy Planning & Resources Committee conducted this meeting remotely.
CALL TO ORDER & ROLL CALL
Chair Parkhurst called the meeting to order at 12:15 p.m. and, Raynette Tom, Executive Assistant, conducted roll call.
ROLL CALL
Alhambra Jeffrey Maloney Committee Member Remote
Carson Reata Kulcsar Committee Member Remote
Culver City Daniel Lee Committee Member Remote
Oxnard Kathleen Mallory Committee Member Absent
Sierra Madre Robert Parkhurst Chair Remote
South Pasadena Diana Mahmud Committee Member Remote
Thousand Oaks Helen Cox Committee Member Remote
All votes are unanimous, unless otherwise stated.
GENERAL PUBLIC COMMENT
There was no public comment.
CONSENT AGENDA
1. Approve Minutes from August 24, 2022, Energy Committee Meeting
2. Receive and File August 2022 Risk Management Team Report Motion: Committee Member Mahmud, South Pasadena
Second: Committee Member Cox, Thousand Oaks
Vote: The consent agenda was approved by a roll call vote.
REGULAR AGENDA
3. Review Energy Procurement Update
John McNamara, Director, Structured Contracts, and Natasha Keefer, Vice President, Power Supply, provided a presentation on energy procurement. Mr.
McNamara reviewed the Mid-Term Reliability (MTR) decision issued by the California Public Utilities Commission (CPUC) in 2022 and discussed CPA’s current MTR compliance position from 2023 to 2026. CPA is currently short in baseload renewables and long-duration storage by 2026 and will need to conduct Agenda Page 3
Clean Power Alliance Energy Planning & Resources Committee Page 2 of 4 September 28, 2022
more procurement to meeting its compliance obligation. Mr. McNamara described some of the challenges leading to delays in projects. Mr. McNamara discussed the PPA Price Refresh Process and explained that the process is designed to allow offers from existing project developers to refresh prices and modify online dates on contracts. Mr. McNamara reviewed the guidelines for the PPA Price Refresh described selection considerations, and next steps. The process is intended to reduce CPA’s risk of compliance penalties, avoid higher costs to meet renewable energy demand and resource adequacy, and support CPA’s reputation as an entity that meets its compliance and obligations. Mr. McNamara outlined the 2022 MTR Request for Offers (RFO), reviewed the 43 offers received by CPA, and provided a breakdown of the offers by product and technology type, location, commercial online date (COD), and generation capacity. Lastly, Mr. McNamara covered key considerations for CPA moving forward, specifically that projects with 2024 online dates are limited and supply-chain challenges and increased costs can elevate prices for CPA’s 2022 RFO.
Responding to Committee Member Mahmud’s question regarding changes in amounts of megawatts of new reliable capacity, Ms. Keefer noted that the CPUC decision includes a process for adjusting procurement targets if there is a significant load migration. In response to Committee Member Cox’s question regarding offers, Mr. McNamara specified that there were seven contracts not addressed by previous amendments that had requested price increases and participated in the PPA Price Refresh Process. Committee Members Mahmud and Cox inquired about the higher number of long-duration storage as opposed to short-term storage. Staff explained an 8-hour battery has the same amount of output as a 4-hour battery, but the duration of the storage is twice as long.
Responding to Committee Member Cox’s question regarding procuring existing baseload capacity, staff indicated that the mid-term reliability decision calls for new incremental capacity; under the narrow definition in the decision, baseload renewables require that the technology achieves an 80% capacity factor, which qualify geothermal and biomass and but not hydro. Chair Parkhurst commented that elevated pricing and the limited projects with a 2024 online date are concerning but staff has been diligent in managing the market conditions.
Ms. Keefer reviewed Southern California Edison’s (SCE’s) long-term Resource Adequacy (RA) agreement. The CPUC ordered IOUs to make a one-time offer of the resource adequacy that was procured under their IRP procurement track mandate to the departed load. This load included Westlake Village, so CPA has the option to enter into an agreement with SCE to buy the RA capacity from SCE’s IRP procurement track resources at the system RA market price benchmark.
4. Approve Staff to Proceed with Negotiations of an Amendment to the Power Purchase Agreement with Arlington Energy Center for Incremental Solar and Storage Capacity as Recommended by the Review Team
Mr. McNamara provided a presentation on the Arlington Solar and Storage PPA amendment. Mr. McNamara reviewed the background of the Arlington storage project; identified the project valuation and viability; and identified the reasons behind the recommendation to approve amendment negotiations for the incremental Arlington 93-megawatt solar and 12-megawatt storage capacity, as recommended by the Review Team who simultaneously reviewed this project in the context of the Price Refresh Process.
Agenda Page 4
Clean Power Alliance Energy Planning & Resources Committee Page 3 of 4 September 28, 2022
Motion: Committee Member Mahmud, South Pasadena
Second: Committee Member Maloney, Alhambra
Vote: Item 4 was approved by a roll call vote with abstention from Committee Member Kulcsar.
5. Review IRP Results
Ms. Keefer provided a presentation on initial 2022 Integrated Resource Plan (IRP) scenario results. Ms. Keefer reviewed the full portfolio of resources for the base case results and its comparison to the previous 2020 IRP results. Ms. Keefer discussed the amount of generation by resource type, noting that the RPS content of CPA’s portfolio is far above the 60% RPS compliance mandate in all study years.
Under this initial scenario, CPA will see a ramp up of long-term PPAs and then transition to buying most load requirements from long-term PPAs rather than market purchases. With regard to reliability, Ms. Keefer pointed out that CPA will still continue to rely on short-term RA contracts with existing resources in the future, but staff will ensure CPA is not over relying on system resources.
In response to Committee Member Mahmud’s question regarding hydro power, Ms. Keefer explained that in the previous IRP the Lean Power product category was filled predominantly with carbon-free procurement while the current IRP defines the Lean Power product differently; there is some existing hydro procurement, but it is far less. Committee Member Mahmud expressed concern that CPA will rely on the market for 50% of RA in 2037 and asked if there is an assumption of significant economic risk. Ms. Keefer specified that the model does optimize around an RA price forecast but also includes the two options to build new resources or buy RA at short-term market prices. The model indicates that the most cost optimal outcome is to build up to 50% new resources and buy the remainder in market; the RA price forecast is a variable, and the CPUC significantly devalued what new resources will count for towards RA in the future, creating diminishing returns on investments in new resources. Committee Member Mahmud inquired if there is an assumption that the significant reduction is due to a degradation of the batteries. Ms. Keefer explained that the CPUC assumes that more battery penetration yields less contribution to reliability by each additional megawatt.
Ms. Keefer discussed a recent CPUC proposal for the design of a mid-to-long term procurement program for ensuring reliability and reducing greenhouse gas emissions. Part of this proposal specified that the Load Serving Entities (LSEs) IRP filings could turn into binding procurement mandates, starting with the 2022 IRP. CPA is working with CalCCA to file comments to oppose the proposal.
However, staff won’t have clarity until Q1 of 2023 on this proposal, so it needs to assess whether the risk should be addressed in the IRP, specifically, staff must ensure it is not overcommitting to a resource buildout that it can’t fill or shouldn’t fill depending on market conditions. Staff may need to convene a special meeting of the Energy Committee to discuss the issue further. Responding to Committee Member Mahmud’s question, Mr. Bardacke indicated that staff will continue to assess the responses of other LSEs to the proposal. In response to Committee Member Cox’s questions, staff indicated that a review team will be formed for the MTR compliance to bring a recommended shortlist to the Energy Committee at the November meeting.
6. Overview of Power Ready RFO
This agenda item was not presented.
Agenda Page 5
Clean Power Alliance Energy Planning & Resources Committee Page 4 of 4 September 28, 2022
COMMITTEE MEMBER COMMENTS
Committee Member Kulcsar requested an informational update from staff on the risks associated with standalone battery storage facilities, as there was recently a fire at a battery storage facility and mention of toxins released into the atmosphere. Committee Member Mahmud commented that, given the fragility of the California grid, it is striking that the CPUC would ask load serving entities to make far-reaching future commitments in the context of unanticipated market conditions. Staff indicated there are no Tesla batteries currently in use, but future project developers have the option to use any battery manufacturer they want. Committee Member Cox thanked staff for all their hard work and for keeping the Committee so well-informed.
ADJOURN
Chair Parkhurst adjourned the meeting at 1:50 p.m.
Agenda Page 6
Staff Report – Agenda Item 2
To: Clean Power Alliance (CPA) Energy Committee
From: Geoff Ihle, Director of Market Risk
Approved by: David McNeil, Chief Financial Officer
Subject: September 2022 Risk Management Team Report
Date: October 26, 2022
September 2022 RMT REPORT
Key Actions
• Reviewed August 2022 market performance
• Reviewed August 2022 generation performance
• Reviewed energy positions and approved 2022-2025 hedges • Reviewed positions for RPS and carbon free products
• Reviewed Resource Adequacy (RA) positions, including CPA’s 2023 Year-Ahead open position
• Reviewed September 2022 CRR Allocations and Auction
Policy Compliance
Policy Deviation Required Action
Due to an update to the load forecast
(resulting in higher forecast energy usage)
and a delay in commercial online dates of
two projects under long term contract
(resulting in lower forecast supply), the Q2
and Q3 2023 periods did not meet the
85% Energy Risk Hedging Strategy
minimum.
The ERMP does not require immediate
action to address the policy deviation.
The Q2 2023 deviation was resolved in
September 2022 as CPA acquired
additional hedges. Based on planned
hedging activities, the Q3 2023 deviation
is expected to be resolved by the end of
December 2022.
ATTACHMENT
None.
Agenda Page 7
Staff Report – Agenda Item 3
To: Clean Power Alliance (CPA) Energy Committee
From: Natasha Keefer, Vice President, Power Supply
Approved by: Ted Bardacke, Chief Executive Officer
Subject: 2022 Integrated Resource Plan (IRP)
Date: October 26, 2022
RECOMMENDATION
Approve the 2022 Integrated Resource Plan (IRP) for submission to the California Public Utilities Commission.
ATTACHMENT
1. 2022 IRP Presentation
2. 2022 Integrated Resource Plan
Agenda Page 8
Item 3
2022 Integrated
Resource Plan Filing
October 26, 2022
1 ENERGY COMMITTEE - ITEM 3 - ATTACHMENT 1
Agenda Page 9
CPA is required to file its 2022 IRP by November 1st
The filing requires Board approval; during its September Board meeting, the Board delegated IRP approval authority to the Energy Committee
The Board packet includes the proposed IRP Narrative document, which is consistent with the specific format and guidelines required by the CPUC
CPA will be submitting only one Preferred Conforming Portfolio that meets the most aggressive GHG reduction targets required by the CPUC
CPA’s portfolio balances CPA’s internal environmental objectives, the CPUC requirements, and minimizes regulatory risks
Action Requested: Approve the proposed 2022 Integrated Resource Plan for submission to the CPUC Executive Summary
2 Agenda Page 10
Agenda
Regulatory Risk
Proposed Portfolio
Action Requested
3 Agenda Page 11
Regulatory Risk
4 Agenda Page 12
Regulatory Risk
On September 8, 2022, the CPUC Energy Division staff released a paper exploring options for the design of a mid-to-long-term procurement program for ensuring reliability and reducing greenhouse gas emissions
Part of this proposal included that the LSE IRP filings could be binding procurement mandates, starting with the 2022 IRP
On October 3rd, CPA met with Energy Division to discuss the proposal CPA is working with CalCCA to file comments opposing this proposal, which are due on December 12th
CPA will not have clarity on this proposal until much later than the November 1st submission of the 2022 IRP (likely Q1 2023)
To mitigate the risk of binding procurement, CPA has adjusted its proposed portfolio to reflect only new procurement that it has a high level of certainty will be achievable, particularly in the near to medium term
5 Agenda Page 13
Proposed
Portfolio
6 Agenda Page 14
Proposed Portfolio
The CPUC is allowing more leeway in the 2022 IRP for internal assumptions; therefore, staff used its own internal resource cost assumptions for modeling purposes, which are more conservative than the CPUC’s assumptions
Although the plan includes the development of approx. 4,445 MW of new resources, CPA’s portfolio continues to rely on existing resources to meet its capacity requirements (although not relying more than our load share of system resources) Not yet contracted, new build resources reflect an achievable level of procurement given current market conditions and resource availability
7 Agenda Page 15
Submission Case Results (Full Portfolio)
0 1,000
2,000
3,000
4,000
5,000
6,000
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 CPA Total Buildout (Cumulative MW) - By Technology and Contracted vs Planned Contracted Resources 4-Hour Battery Storage (Li-Ion) 8-Hour Long Duration Storage Geothermal Solar PV Wind (onshore) Wind (Offshore)
0 1000
2000
3000
4000
5000
6000
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 CPA Total Buildout (Cumulative MW) - By Technology
4-Hour Battery Storage (Li-Ion) 8-Hour Long Duration Storage Geothermal Solar PV RPS Hydro Wind (onshore) Wind (Offshore)
CPA’s IRP reflects a diverse mix of resources (solar, onshore wind, offshore wind, geothermal, and storage) and takes advantage of CPA’s early commitment to contracting for new build resources 8 Agenda Page 16
Proposed Incremental Build
Load: Mid-case (CPUC assigned)
Market Price: Mid-case
Resource Costs: CPUC assumptions
CPA RPS/CF Targets: Low Scenario
CPA plans to bring new
incremental resources online
starting in 2026 to meet Mid-Term Reliability requirements and CPA’s RPS and RA needs
Longer development resources,
such as onshore and offshore
wind, are added to the study
period in the 2030-2035
timeframe
9 Agenda Page 17
GHG Emissions Targets
Load: Mid-case (CPUC assigned)
Market Price: Mid-case
Resource Costs: CPUC assumptions
CPA RPS/CF Targets: Low Scenario
To balance affordability and meeting environmental targets, the proposed submission case was designed to just exceed the 25 MMT 2030 and 2035 GHG benchmark:
Metric 2030 GHG Emissions (MMT) 2035 GHG Emissions (MMT) Emissions Benchmark for CPA 1.049 0.848
CPA Portfolio Results 1.042 0.845
10 Agenda Page 18
Portfolio RPS Content
Annual Generation by Resource Type (MWh)
CPA achieves 100% renewable energy content by 2030
11 Agenda Page 19
Reliability
CPA meets its reliable capacity
needs with a mix of long-term
contracts and short-term RA
purchases with existing resources
(in brown)
CPA’s short-term RA purchases
are significantly below its load-share of total system resources Storage is the largest contributor
to reliability
-
500
1,000
1,500
2,000
2,500
3,000
2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 CPA Reliability Need (MW)
Storage Onshore Wind Offshore Wind Solar Geothermal RPS Hydro Short-Term RA CPA Reliability Need Reliability need values are provided by the CPUC and representative of CAISO’s marginal reliability need
12 Agenda Page 20
Procurement Cost Estimate
CPA developed its
procurement cost estimate
using its internally
developed resource cost
assumptions, which are
more conservative than the
CPUC assumptions
Under the IRP plan, CPA’s
power procurement costs
are expected to increase at
an average rate of 1.4%
between 2023-2035
Costs mostly decline or are
flat until 2033 with the
procurement of offshore
wind
13 Agenda Page 21
Summary
The CPA plan achieves the State’s lowest GHG emissions portfolio (25 MMT), while meeting CPA’s environmental targets and maintaining stable costs The portfolio reflects a diverse set of resources to meet California’s reliability needs and balances RA procurement from existing and planned resources The new build resource plan represents an achievable procurement path while following through on CPA’s commitment to bring new clean energy resources to the grid 14 Agenda Page 22
Action
Requested
15 Agenda Page 23
Action Requested
Approve the proposed 2022 Integrated Resource Plan
for submission to the CPUC
16 Agenda Page 24
Template posted by Commission on June 15, 2022
2022 INTEGRATED RESOURCE PLAN
NOVEMBER 1, 2022
Construction of CPA’s High Desert Solar + Storage project, which achieved commercial operation on December 17, 2021 ENERGY COMMITTEE - ITEM 3 - ATTACHMENT 2
Agenda Page 25
1 Table of Contents
I. Executive Summary.................................................................................................................... 3 II. Study Design................................................................................................................................. 5 a. Objectives.................................................................................................................................... 6 b. Methodology ............................................................................................................................. 7 i. Modeling Tool(s)................................................................................................................. 8 ii. Modeling Approach.........................................................................................................11 a. Conforming and Alternative Portfolios.........................................................................17 b. Preferred Conforming Portfolios.....................................................................................19 c. GHG Emissions Results ........................................................................................................23 d. Local Air Pollutant Minimization and Disadvantaged Communities ...............23 i. Local Air Pollutants ..........................................................................................................23 ii. Focus on Disadvantaged Communities ..................................................................23 e. Cost and Rate Analysis.........................................................................................................27 f. System Reliability Analysis ................................................................................................. 30 g. High Electrification Planning.............................................................................................31 h. Existing Resource Planning................................................................................................32 i. Hydro Generation Risk Management............................................................................32 j. Long-Duration Storage Planning ....................................................................................34 k. Clean Firm Power Planning................................................................................................34 l. Out-of-State Wind Planning .............................................................................................35 m. Offshore Wind Planning......................................................................................................36 n. Transmission Planning.........................................................................................................37 III. Action Plan ..................................................................................................................................38 Proposed Procurement Activities and Potential Barriers ......................................38 a. 38
i. Resources to meet D.19-11-016 procurement requirements .......................38 ii. Resources to meet D.21-06-035 procurement requirements, including: . 39 a. 1,000 MW of firm zero-emitting resource requirements ................................39 Agenda Page 26
2 b. 1,000 MW of long-duration storage resource requirements ........................40 c. 2,500 MW of zero-emissions generation, generation paired with storage, or demand response resource requirements ...............................................................40 d. All other procurement requirements .......................................................................41 iii. Offshore wind.....................................................................................................................41 iv. Out-of-state wind.............................................................................................................42 v. Other renewable energy not described above ....................................................42 vi. Other energy storage not described above..........................................................42 vii. Other demand response not described above....................................................42 viii. Other energy efficiency not described above......................................................42 ix. Other distributed generation not described above...........................................42 x. Transportation electrification, including any investments above and beyond what is included in Integrated Energy Policy Report (IEPR)..................42 xi. Building electrification, including any investments above and beyond what is included in Integrated Energy Policy Report (IEPR)...................................43 xii. Other......................................................................................................................................43 b. Disadvantaged Communities............................................................................................43 c. Commission Direction of Actions....................................................................................45 IV. Lessons Learned........................................................................................................................45 Agenda Page 27
3 I. Executive Summary
Clean Power Alliance of Southern California (CPA) is a Load Serving Entity (LSE) and administrator of a Community Choice Aggregation (CCA) program. Formed as a Joint Powers Authority (JPA), CPA’s 32 member jurisdictions include the unincorporated areas of Los Angeles and Ventura Counties, as well as the cities of Agoura Hills, Arcadia, Alhambra, Beverly Hills, Calabasas, Camarillo, Carson, Claremont, Culver City, Downey, Hawaiian Gardens, Hawthorne, Malibu, Manhattan Beach, Moorpark, Ojai, Oxnard, Paramount, Redondo Beach, Rolling Hills Estates, Santa Monica, Sierra Madre, Simi Valley, South Pasadena, Temple City, Thousand Oaks, Ventura, West Hollywood, Westlake Village, and Whittier. CPA serves approximately 1 million customer accounts representing over 3 million residents and businesses.
CPA is governed by a board of directors comprised of elected officials of its member cities and counties, which span a broad territory that is diverse in its geography, climate, and customer demographics.
CPA began offering service to municipal customers of unincorporated Los Angeles County in February 2018 and began service to non-residential customers of unincorporated Los Angeles County, Rolling Hills Estates, and South Pasadena beginning in June 2018. CPA enrolled residential customers from 31 of its member jurisdictions in February 2019 and completed enrollment of its current non-residential customers in May 2019. Both residential and non-residential customer enrollments in Westlake Village occurred in June 2020.
As set out in its Joint Powers Agreement, CPA is a mission-driven organization. CPA intends to develop an electric supply portfolio with overall lower greenhouse gas (GHG) emissions than that of the local Investor Owned Utility (IOU), Southern California Edison (SCE). CPA’s procurement policy encourages the use and development of cost-effective renewable and distributed energy resources and discourages the use of unbundled renewable energy credits (RECs). CPA also intends to manage its energy portfolio and products in a manner that provides cost savings to customers, promotes public health in areas impacted by energy production, supports regional economic benefits and workforce development, and offers customers a choice of differentiated renewable products.
Now in its fourth year of operations, CPA is relying on short- and long-term procurement to meet the needs of its current customers and offers three renewable products while remaining price-competitive and satisfying regulatory requirements. The three supply options that CPA offers to its customers are:
Lean Power, which provides a State compliance renewable portfolio content; Clean Power, which provides 50% renewable energy content; and 100% Green Power, which provides 100% renewable energy content. CPA procures electricity for its customers from a variety of resources guided by policies adopted by the CPA Board of Directors (Board), and by regulatory requirements established by the legislature and state regulatory agencies.
Consistent with CPA’s governance practices and Public Utilities Code section 454.52, this Integrated Resource Plan (IRP) was approved on October 26, 2022, by the CPA Energy Planning & Resources Committee, the standing committee to whom the Board delegated authority for approval of the IRP through formal action on September 1, 2022, similar to what occurred with CPA’s 2018 and 2020 IRP.
Agenda Page 28
4 CPA is committed to providing safe, reliable, affordable, and clean energy to its customers and seeks to collaborate with statewide energy stakeholders to support California’s energy goals.
CPA developed an IRP model that provides resource procurement trajectories to support CPA in meeting its regulatory requirements and renewables and emissions goals at a reasonable cost to ratepayers. The future resources identified in CPA’s IRP represent CPA’s best good-faith projection of the resource mix that it will seek to procure over the IRP planning horizon, based on the best information currently available. The resources identified in future iterations of CPA’s IRP may change due to new information and changed circumstances, and the ultimate resource mix that CPA actually procures may differ from what is reflected in the plan due to a number of variables including availability of supply, price of supply, and/or other market or regulatory considerations.
CPA developed one preferred IRP Conforming Portfolio consistent with the 30 MMT GHG target in 2030 and 25 MMT GHG target by 2035, using assumptions that are consistent with the California Public Utilities Commission’s (CPUC) system modeling. In calculating its emissions, CPA used the CPUC’s Clean System Power (CSP) calculator to ensure that CPA’s portfolio emissions are at or below the CPUC benchmarks for CPA. The preferred portfolio modeling results in an action plan (Action Plan) that is consistent with several clean energy procurement trends. The portfolio consists of long-term wind and solar resources, with 4-hour and 8-hour long duration storage projects added to promote reliability.
CPA procurement also includes geothermal resources as the system gets saturated with solar, and offshore wind as onshore wind potential nears exhaustion. CPA’s preferred portfolio results are broadly consistent with the trends seen in the CPUC’s Reference System Plan.
The assumptions embedded in the preferred portfolio are consistent with the filing requirements and the results reflect CPA’s goal to provide its customers with clean, reliable, and reasonably priced energy.
CPA will align its procurement with this preferred portfolio as long as procurement can be conducted consistent with our communities’ local goals, and are subject to change based on needs to minimize customer risk, resource availability, changing market conditions, and potential new regulatory obligations. CPA will also maintain a diverse resource mix and minimize curtailment to contribute its share of grid reliability. Beyond the CPUC’s mandates within the scope of this IRP proceeding, CPA’s internal procurement planning process is driven by CPA Board-established policies and procedures, and in conjunction with CPA’s Community Advisory Committee and other community stakeholders.
Given CPA’s obligation to reliably meet customers’ needs, the Action Plan calls for significant investment in new build renewable resources as well as strategic use of existing facilities. In addition, CPA seeks to establish a resource portfolio that encourages the use and development of cost-effective local renewable and distributed energy resources.
CPA believes that the recommended Action Plan provides for an optimal combination of expected costs and associated risks, while retaining the flexibility to take advantage of market-driven resource innovations and local stakeholder priorities. It provides CPA an excellent opportunity to deliver safe, clean, reliable, and affordable energy to our customers in an increasingly sustainable way. The Action Agenda Page 29
5 Plan takes full advantage of technologies and markets to enable a smarter, greener, and more flexible resource portfolio.
II. Study Design
This section describes the process used by CPA to develop its IRP. In this IRP, CPA demonstrates that it has a clear plan to meet its CEC 2021 IEPR load forecast through 2035 with a reliable resource portfolio comprised of carbon free energy and RPS-eligible energy resources.
To develop its IRP, CPA used:
• Inputs that were consistent with the CPUC Reference System Plan • An IRP model developed to determine least-cost resource procurement options to meet CPA’s emissions goals and regulatory requirements
• The CSP methodology to calculate its emissions and ensure compliance with the emissions benchmark assigned to CPA
Load Assignments for Each LSE
CPA’s annual base load forecast and load modifiers are consistent with the assigned forecast from the ALJ June 15, 2022, Ruling Finalizing Load Forecasts and Greenhouse Gas Emissions Benchmarks for 2022 Integrated Resource Plan Filings. For modeling in PLEXOS, CPA derived an hourly load profile, including all load modifiers, consistent with the CEC’s “mid Baseline mid AAEE” 2021 IEPR data and ensuring that the total annual energy volumes for load remains consistent with CPA’s assigned forecast, as shown in Table 1 below:
Table 1: CPA Load Forecast
CPA’s annual peak capacity forecast is consistent with the confidential forecast assigned to CPA by Energy Division staff on July 1, 2022, and CPA’s capacity planning reflects a 14% Planning Reserve Margin.
Within CPA’s CSP, CPA used the template load modifier shapes (i.e., did not use custom load profiles).
Required and Optional Portfolios
CPA’s IRP presents a strategy for meeting CPA’s energy and capacity needs and is guided by the goals and policies established by CPA’s Board and the State’s procurement requirements for load-serving entities. Notably, this includes California’s renewable portfolio standard (RPS) and GHG emission obligations. CPA has established electricity supply goals and policies as described in the Objectives CPA 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 CPA Sales Forecast (GWh) 10,902 11,015 11,087 11,155 11,249 11,321 11,398 11,467 11,543 11,590 11,643 11,692 11,744
Agenda Page 30
6 section below. In applying the goals and policies to CPA’s portfolio, CPA analyzed different options for electricity supply procurement over a planning horizon from 2023-2037.
For the purpose of this 2022 IRP Filling, CPA has developed one Preferred Conforming Portfolio which uses a load forecast consistent with the requirements of the June 15, 2022, ALJ Ruling, and inputs and assumptions consistent with those used by the staff to develop the Reference System Portfolio (RSP).
The Conforming Portfolio meets CPA’s assigned GHG benchmarks under the 2030 30 MMT and 2035 25 MMT scenario and conforms to CPA’s policy objectives to achieve an electricity supply with zero GHG emissions.
CPA is not submitting additional Alternative Portfolios.
GHG Emissions Benchmark
CPA developed and evaluated its portfolio using its specific GHG emissions benchmarks as assigned in the Finalizing ALJ Ruling for the 25 MMT portfolio (1.049 MMT for the 2030 GHG Emissions Benchmark and 0.848 MMT for the 2035 GHG Emissions Benchmark). CPA used the CSP methodology and CSP Calculator Tool for GHG accounting and determining the emissions associated with CPA’s Conforming Portfolio. CPA determined that its portfolio emissions were aligned as closely as practical with the GHG emissions benchmarks, net of behind-the meter combined heat and power1, assigned to it under the CSP methodology. This resulted in portfolio with emission benchmarks under the assigned values. The table below shows the respective 2030 and 2035 GHG emissions benchmarks for the 25 MMT GHG portfolio, net of behind-the meter combined heat and power, and CPA Preferred Conforming Portfolio results.
Table 1: CPA Portfolio GHG Results
Metric 2030 GHG Emissions (MMT) 2035 GHG Emissions (MMT) Emissions Benchmark for CPA 1.049 0.848
CPA Portfolio Results 1.042 0.845
a. Objectives
CPA is committed to complying with the CPUC’s IRP process to meet its obligation of serving customers reasonably priced and reliable electricity and meeting or exceeding California’s emissions reductions goals. CPA intends to comply with all statutory and regulatory goals and requirements, including SB 350, SB 100, SB 1020, and Resource Adequacy (RA).
1 Individual LSEs are not required to plan to reduce BTM CHP emissions, but the CPUC counts these emissions towards the electric sector emissions total and are included in LSE GHG Benchmarks. The CPUC will account for BTM CHP emissions when calculating electric sector emissions of the aggregated LSE portfolios during the development of the Preferred System Plan.
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7 CPA’s approach was intended to adhere to the 25 MMT GHG target portfolio, consistent with CPUC’s adopted assumptions. In addition, CPA’s preferred portfolio reflects two key priorities of CPA’s communities:
• Beyond the state’s minimum renewable procurement requirements, CPA’s Board has established additional requirements for renewable procurement via its product offerings and community default rate selections, which pursue aggressive renewable energy targets. As described in the Executive Summary, CPA offers its customers the options of Lean, Clean, and 100% Green rates, which correspond to various renewable energy content percentages (minimum RPS compliance, 50%, and 100%, respectively). Approximately two-thirds of CPA’s customers receive service at the 100% Green rate, which means that CPA serves these customers with 100% RPS-certified energy. Due to this additional voluntary procurement to meet its customers’ demand for renewable energy resources, CPA is expected to meet and exceed its SB 100 target of 60% renewable energy in 2023 and beyond, much earlier than the 2030 RPS compliance target. CPA assumes a modest growth in RPS portfolio content over time as demonstrated in the Preferred Conforming Portfolio. A substantial driver of the increase in CPA’s contracted new renewable capacity is reflective of CPA’s transition from meeting renewable energy demand from short-term contracts with existing resources to long-term power purchase agreements with new build renewable resources, which is a priority for CPA’s communities.
• Per its Joint Powers Agreement, CPA has a goal of achieving overall lower GHG emissions than that of the local IOU. In order to achieve this internal GHG target, beyond the renewable energy procurement CPA conducts to meet its customer demand obligations, CPA also procures non-RPS carbon free resources from existing large hydro resources. Assumptions about this procurement is described in more detail in the Methodology section.
Table 2: CPA Internal RPS and GHG-Free Targets by Year
CPA’s portfolio was developed and optimized around these internal RPS and GHG-free goals and which are below the CPUC 25 MMT GHG benchmark. In addition, CPA selected the portfolios that minimize negative impacts and emphasizes benefits for Disadvantaged Communities (DACs) and reduce market risks for energy procurement through long-term acquisition of renewable resources at fixed price. b. Methodology
The goal of the IRP is to identify a mix of new and existing resources that provides the best combination of expected costs, and associated risks and uncertainties for CPA and its customers. This Section provides an overview of the data, analytical tool, and methods CPA uses to assess resource portfolio performance in this IRP.
CPA 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 RPS 77% 83% 85% 86% 87% 87% 88% 88% 89% 89% 90% 91% 91% GHG-Free 80% 85% 88% 91% 91% 92% 92% 94% 95% 96% 97% 97% 97% Agenda Page 32
8 i. Modeling Tool(s)
The modeling software used to develop the IRP was Energy Exemplar’s PLEXOS production cost modeling software (PLEXOS®). The version used is PLEXOS® 8.300 R11, released on May 12, 2022.
PLEXOS® is a chronological unit commitment model, which works to simulate the economic dispatch of power plants within a competitive market framework. The model uses a mixed integer linear programming (MIP) approach to capture details of power plant while observing real world constraints.
Constraints include items such as emission reduction targets, plant operating limits, renewable energy availability and mandatory portfolio targets. PLEXOS® is widely used by electric utilities, consulting agencies, and other stakeholders for the purpose of forecasting generator performance and economics, developing IRPs, forecasting power market prices, assessing detailed impacts of regulatory and market changes impacting the electric power industry, and to generate financially optimized generating portfolios. The model can assess the potential performance and capital costs of existing and prospective generation technologies and resources, and make resource addition and retirement decisions for economic, system reliability, and policy compliance reasons on a utility system.
The CPUC uses RESOLVE to develop the RSP, which identifies the new resources that meet the GHG emissions planning constraint. As opposed to PLEXOS®, which models each generator independently, the RESOLVE model groups together resource categories with similar operational characteristics (e.g., nuclear, coal, gas CCGT, gas peaker, renewables) and models them collectively. RESOLVE uses a linearized unit commitment where the commitment variable for each class of generators is a continuous variable rather than an integer variable. PLEXOS® has more rigorous unit commitment and dispatch methodologies as compared to RESOLVE. PLEXOS® models the operating cost and performance parameters on a plant-level basis, where the optimization method uses a mixed MIP to determine unit commitment. Based on public documents, RESOLVE is run for a sampled 37 days in a year and only for a few years, therefore, only representative load and renewable profiles were selected to reflect system conditions. CPUC uses SERVM as a separate tool to examine system reliability and simulate production cost. PLEXOS® is both a Long-Term Capacity Expansion Planning (LT Plan) and a production cost model.
In the long-term capacity expansion process, CPA used a Long-term Capacity Expansion module to determine optimal renewable generation investment (or retirement) to meet projected CPA load growth while still complying with reliability criteria, emission limits, and RPS and GHG free targets.
A summary of the methodology with key inputs, algorithms, and outputs is shown below:
Figure 1: PLEXOS inputs and Outputs
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9 PLEXOS® is an hourly, chronological production cost model with an integrated LT Plan feature that produces a resource expansion plan given resource options and constraints around those options. The options can include supply and demand generic resources, including storage, for inclusion in the expansion plan, existing resources, and existing resources for economic retirement as desired. The full set of standard operational and cost parameters for new and existing resources are considered in the LT PLAN, providing a robust framework from which to evaluate different technologies with different operational (intermittent vs. baseload) cost and incentive profiles. The LT Plan considers constraints such as reserve margin targets or requirements, renewable portfolio standards, carbon limits, and ancillary service constraints.
PLEXOS® minimizes production costs and can assign practically any rule with the constraint, decision variable such as:
• System capacity reserve margins & ancillary services
• Maximum number of units built and retired
• Technical and Financial life spans
• Fuel availability and maximum fuel usage
• Minimum energy production
• Emission production limits and renewable energy targets • Hydroelectric storage targets and releasing policies
CPA’s long-term capacity expansion logic is illustrated in the Figure below. The LT Plan makes use of an iterative logic to develop a regional capacity expansion plan. At the end of any given iteration, it has the information it needs to take retirement actions on existing uneconomic resources and to select economically viable new resource options. Convergence criteria reduces the total number of resource alternatives which are considered by the LT Plan through the iterations, with a converged solution being defined as one in which system prices remain stable even with change in resource alternatives. In other words, the solution reflects an expansion plan that is at once both economically rational and stable.
PLEXOS® uses a dynamic simulation of adding, or retiring, economic capacity with optimization logic to forecast LT resources and retirements. With this approach, PLEXOS® performs an iterative future analysis where:
1. Resources that have negative going-forward value (revenue minus costs) are retired;
2. Resources with positive values are added to the system on a gradual basis, whereby a set of resources with the most positive net present value is selected from the set of new resource options and added to the study;
3. PLEXOS® then uses the new set of resources to compute all the values again; and
4. The process of adding and retiring resources is continually repeated until the system price stabilizes, indicating that an optimal set of resources has been identified for the study.
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10 Figure 2: Long-Term Capacity Expansion
LT Plan finds the optimal combination of generation new builds and retirements and transmission upgrades (and retirements) that minimizes the net present value (NPV) of the total costs of the system over a long-term planning horizon. That is, to simultaneously solve a generation and transmission capacity expansion problem and a dispatch problem from a long-term perspective.
Long-term (LT) Capacity Expansion determines optimal investment decisions over long period of time, usually up to 30 years. The PLEXOS LT-Plan module accomplishes this by minimizing the Net Present Value of forward-looking investment costs and the portfolio production cost. Therefore, the portfolio cost minimization problem is expanded to include the investment cost and the investment-related constraints as follows:
Minimize Portfolio Production Cost + Investment Cost2 Subject to:
• Portfolio operational constraints
• Investment Constraints
The PLEXOS LT-Plan solution is illustrated by the following chart. The x-axis corresponds to the investment and y-axis corresponds to the cost. As the investment increases, the production cost, P(x), decreases and the capital cost, C(x) increases. The total cost is the sum of capital and production cost, C(x)+P(x). The PLEXOS LT Plan simulation returns the optimal investment decision while observing the investment and operational constraints.
2Investment Cost may include cost of new generator builds, cost of transmission expansion, and/or cost of generator investments. The Investment Constraints my include regional capacity reserve margins, resource addition and retirement candidates (i.e., maximum units built / # retired), technical and financial life spans, technology/fuel mix rules, RPS, etc. The build and retirement candidates might include thermal generators, geothermal generators, hydro or pumped storage hydro generators, wind or solar generators, battery and long duration storages, and demand side participation.
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11 Figure 3: PLEXOS LT-PLAN Solution
PLEXOS® and RESOLVE both optimize dispatch for a system under a given set of inputs. RESOLVE is a linear optimization model, which assesses dispatch based on representative days over a defined forecast horizon. PLEXOS® differs in that it is a mixed integer program and hourly chronological dispatch simulation. RESOLVE generally focuses on a single market, reflecting high level interties and market interaction with neighboring regions. PLEXOS® can be set up in several different ways. PLEXOS® can be run for the entire western interconnect.
Both RESOLVE and PLEXOS® identify the optimal resources to meet needs based on the technology options offered including generation and storage. Both models also allow for the incorporation of different types of market and portfolio constraints including renewable generation, carbon emissions (or emission rates), reserve margin, and timing of new build requirements. ii. Modeling Approach
For this IRP, PLEXOS was used to develop a 15-year IRP that simultaneously satisfies system reliability constraints, RPS and GHG targets and minimizes the Net Present Value (NPV) of the sum of investment cost and operation cost over a 15-year planning horizon.
For its IRP modeling, CPA utilized the PLEXOS LT Plan capacity expansion modeling and production cost modeling (“PCM”) simulation software, based on specific requirements of each process step, in creating, analyzing, and validating resource portfolios.
Specifically, CPA used the following two-step iterative process:
1. Step 1: Build the optimized CPA system-wide resource portfolio using PLEXOS LT capacity expansion model to meet the CPA system share of a 25 MMT GHG target, Planning Reserve Margin (PRM) and RPS requirements, and to serve the load of the CPA system load, based on all assumptions for existing and candidate resources.
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12 2. Step 2: Perform the detailed PLEXOS PCM simulation to validate if the CPA system-wide resource portfolio produced by PLEXOS LT capacity expansion model can operate on an expected and deterministic basis, while meeting CPA’s load, satisfying individual generation constraints, and incorporating more detailed emissions calculations to reflect the variation of load and generation and meet the annual GHG target. If there are any unserved load and violations of the above limitations, constraints, and targets, the updated requirements will be implemented to rerun the PLEXOS LT capacity expansion model to create a new resource portfolio.
CPA provides more details on its capacity expansion and production cost modeling in the section below. a) Capacity Expansion Modeling
The capacity expansion model is critical in the IRP process because it is utilized to develop the resource portfolios at least cost. CPA uses PLEXOS LT Plan model to develop its resource portfolios to meet GHG emissions and other constraints. The model seeks feasible solutions that trade-off cost and performance characteristics of a portfolio of existing and candidate resources to meet future demand forecast. The outcome of the model is a capacity expansion plan, sometimes also referred to as capacity additions specified by years in MW (capacity) of a new plant to be built.
CPA runs LT Plan modeling and PLEXOS PCM simulations in sequence to ensure that the least-cost resource portfolio built by LT Plan is operable to meet the hourly demand, PRM, and GHG target in the deterministic PCM simulations, as described further in the next section. b) PCM Simulation
In the IRP process, it is important to conduct PCM simulations to validate the operational feasibility and performance of the portfolios built by the capacity expansion model for the CPA system. A PCM simulation approach is used to dispatch generation resources to meet the demand and PRM requirements of the system on an hourly basis, while satisfying all the generator operational constraints, and other system reliability requirements. Compared to the capacity expansion model, the PCM, which considers the detailed generator characteristics, ramping capabilities, and balancing load on an hourly basis, is an effective tool to assess the operational feasibility of resource portfolios in a power system.
CPA used PLEXOS, a commercial software program with a mixed integer programming optimization engine, to perform the PCM simulation for the CPA system. PLEXOS generates the commitment and dispatch of available generation resources to meet demand and reserve requirements at least cost, subject to transmission and individual generation resource constraints. This modeling approach is a more sophisticated way to determine the dispatch of resources and emissions results as compared to the simplified CSP tool. CPA used both the PCM Simulation and the CSP tool to evaluate portfolio performance and emissions results.
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13 Inputs and Assumptions
CPA’s 2022 IRP inputs and assumptions are consistent with those of the CPUC’s 2022 Inputs and Assumptions document. The following are the same: load forecast, baseline and candidate resources and resource availability, Effective Load Carrying Capacity (ELCC) of candidate resources, technology operational specifications, state’s RPS target, and 30 MMT GHG emissions target or 25 MMT GHG emissions target, depending on case, for the electric sector by 2035. CPA’s long-term forecast result is consistent with the CPUC-assigned load forecast for CPA.
CPA’s forecast for new build resource costs assumptions deviated from the CPUC resource cost assumptions for some resources, as shown below in red:
Table 4: CPA Forecast for New Candidates Resources (Levelized $/MWh) by Online Year Red denotes change from CPUC assumption
CPA made several adjustments to the CPUC resource costs for the following reasons:
• Solar pricing for 2023-2026 was adjusted to account for current elevated pricing conditions; pricing for 2027 and beyond retain the CPUC assumptions given favorable tax credits available in the Inflation Reduction Act.
• Offshore wind costs were adjusted based on recent cost estimates. • Geothermal pricing was increased to reflect inflated demand due to regulatory mandates (i.e., D.21-06-035).
• Battery Hybrid and Long Duration Storage was updated to reflect high near-term costs and higher long-term costs due to elevated demand for lithium.
Large Hydro
($/MWh)
Small Hydro
($/MWh)
Solar
($/MWh)
Wind
onshore
($/MWh)
Wind
offshore
($/MWh)
Geothermal
($/MWh)
Biomass
($/MWh)
Battery
Storage
Hybrid
($/kw-yr)
Battery
Storage
Standalone
($/kw-yr)
Long
Duration
Storage
($/kw-yr)
2023 86 190 35 46 185 80 109 138 138 180
2024 86 190 35 45 185 79 109 138 138 180
2025 86 190 28 44 185 78 109 108 108 141
2026 86 179 25 43 185 77 112 102 102 178
2027 86 175 20 41 185 76 112 96 96 168
2028 86 171 18 40 185 75 112 90 90 158
2029 86 167 17 39 185 74 112 84 84 148
2030 86 163 16 38 150 73 113 78 78 161
2031 86 157 16 37 150 72 113 78 78 163
2032 86 151 16 37 150 72 113 78 78 163
2033 86 145 16 37 150 72 113 78 78 163
2034 86 140 16 36 150 72 113 78 78 164
2035 86 134 16 36 150 71 113 78 78 165
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14 • Battery Standalone was updated to equal hybrid costs to reflect new tax credits available for standalone storage from the Inflation Reduction Act.
Contracted Resources
CPA’s generation supply consists of a mix of geothermal, hydroelectric, wind, solar PV, and battery storage resources. To date, CPA’s Board has approved 17 long-term clean energy power purchase agreements, with hundreds of additional megawatts of new clean energy resources under negotiation.
The table below lists the resource type, status, commercial operation date, and capacity under contract for CPA’s generation supply.
Table 5 Executed Long-term Contracts
Project Resource Type Status
Commercial
Operation
Date
Term Renewable
MWs
Storage
MWs
(Years)
Voyager Wind Online 12/28/2018 15 21.6
Kaweah Hydro Online 6/16/2020 10 20.09
Isabella Hydro Online 12/8/2020 10 11.95
Mohave Wind Online 12/15/2020 20 300
Golden Fields Solar Online 12/21/2020 15 40
Luna Storage Online 8/3/2022 15 100
Sanborn Storage Online 11/15/2021 15 100
High Desert Solar + Storage Online 12/17/2021 15 100 50 Arlington Solar Online 12/31/2023 16 140 120
Rexford Solar + Storage Contracted 12/31/2024 15 300 240 Chalan Solar + Battery Contracted 12/31/2024 15 65 65
Daggett Solar + Battery Contracted 12/1/2023 15 123 61.5 sPower - Estrella Solar + Battery Contracted 12/31/2023 16 56 28 Heber South Geothermal Geothermal Online 1/1/2022 15 14 Resurgence Solar + Battery Contracted 6/1/2023 20 48 40 Arica Solar + Battery Contracted 6/1/2024 15 93.5 71
Daggett 2 Solar + Battery Contracted 12/19/2023 15 65 52 Geysers Geothermal Geothermal Online 1/1/2022 15 50
Desert Quartzite Solar + Battery Contracted 3/1/2025 20 300 150 Azalea Solar + Battery Contracted 12/31/2024 15 60 38
Radiant Solar Contracted 12/31/2023 15 3
Cape Station Geothermal Contracted 6/1/2028 15 33
Dominguez Solar PV - Rooftop Contracted 12/30/2023 15 0.96 El Segundo Solar PV - Rooftop Contracted 12/30/2023 15 0.64 Wilmington 1 Solar PV - Rooftop Contracted 12/30/2023 15 1.8 Agenda Page 39
15 Wilmington 2 Solar PV - Rooftop Contracted 12/30/2023 15 0.6 Workman Solar PV - Rooftop Contracted 12/30/2023 15 1.92 Total 1,850 1,116
CPA provided a list of long-term power purchase agreements (PPAs) currently under contract in the Resource Data Template. The information provided included technology, term, contracted capacity, and generation, among other items. All CPA’s executed PPAs were included in the simulations in the PLEXOS model along with planned resources and new candidate resources selected by the LT Capacity Expansion Model.
Energy Market Assumptions
CPA used long-term energy market price forecasts from a third-party vendor, IHS Markit (IHS), to serve as the basis for analysis of the CPA resource portfolio. CPA used IHS’s June 2022 Planning Case outlook for natural gas, electricity and CO2 emissions prices. The long-term hourly price forecasts for the California – Southern California Edison (CA-SCE) market area were used to model economic purchases.
The price outlook was derived based on a combination of legislative and regulatory requirements and IHS’s long-term economic assumptions, to develop a fundamentals-driven framework for long-term market price forecasts. The chart below summarizes the forecast for electricity prices used in the IRP.
Figure 4: SP15 Annual Average Electricity Price Forecast Average annual electricity prices shown above are expected to gradually increase due to increasing natural gas prices and GHG emission allowance prices. Natural gas resources are still expected to set the market price of electricity in most of the hours. However, as more solar resources enter the market there are times when solar displaces natural gas generation and sets the hour price of power. The market is seeing zero and negative electricity prices during hours when solar generation exceeds energy demand.
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16 The figure below shows the impact increasing solar penetration has on hourly electricity prices on a typical spring and summer day in California in 2024.
Figure 5: Hourly SP15 Electricity Price Forecast Comparison Post Processing
As part of the 2022 IRP filing, CPA developed several post-processing calculations that were used to generate metric for the portfolio. The post-processing calculations encompassed cost metrics, emissions metrics and a few other miscellaneous metrics. Almost all the calculations were based off outputs from the PLEXOS model. Critical post-processed calculations are discussed below.
To provide deeper insights into the generation and emission profiles of the portfolio, several metrics were developed to test compliance with CPUC requirements and CPA’s internal portfolio targets. Post-processing calculations were considered for the RPS and GHG-free positions of the portfolio. The PLEXOS model did not include the ability for CPA to procure attribute-only contracts to meet RPS and RA procurement targets. As a result, a post-processing calculation was created to identify any additional PCC1 REC products from existing system resources that would be required to procure to meet/exceed the CPUC RPS requirements and meet internal requirements.
Metrics included:
• Long-term Contracting Requirements (MWh)
• Pre-Procurement RPS % of Load
• Pre-Procurement GHG-free % of Load
• Additional short-term PCC1 REC Purchases
• Additional short-term RA Purchases
0 10
20 30
40 50
60 70
80 90
MW
Mar-24 Aug-24
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17 Curtailment
The PLEXOS model determines curtailments for solar, wind and other non-dispatchable resources on an hourly basis based on load requirements, battery storage charging and economics. During a specific hour of the day, for instance during solar hours, if there is excess generation, the PLEXOS model determines how much of that excess generation is used to charge batteries and how much would be curtailed. Results of curtailment are presented in the System Reliability section.
Study Results
a. Conforming and Alternative Portfolios
CPA has selected one preferred portfolio that balances procurement flexibility in the near-term and a resource mix that minimizes costs to ratepayers based on NPV, while meeting regulatory requirements, and achieving emissions that are less that CPA’s proportional share of the 30 MMT by 2030 and 25 MMT by 2035 GHG targets. The table and figure below provide a summary of the resources provided in the Resource Data Template.
Table 6: Summary of 25 MMT Portfolio in Cumulative Nameplate MW CPA is expecting to bring a significant number of new clean resources to California, 4,445 MW by 2035 in its preferred Conforming Portfolio, as shown in the Figure below. 25 MMT 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 Contracted Resources 1,550 2,483 2,933 2,933 2,933 2,966 2,966 2,966 2,934 2,934 2,934 2,912 2,912 Solar 581 1,099 1,399 1,399 1,399 1,399 1,399 1,399 1,399 1,399 1,399 1,399 1,399 Onshore Wind 322 322 322 322 322 322 322 322 322 322 322 300 300 RPS Hydro 32 32 32 32 32 32 32 32
Battery Storage 552 966 1,116 1,116 1,116 1,116 1,116 1,116 1,116 1,116 1,116 1,116 1,116 Geothermal 64 64 64 64 64 97 97 97 97 97 97 97 97
Planned Resources 0 0 0 907 1,007 1,007 1,007 1,717 1,717 1,717 2,087 2,087 2,487 Existing Large Hydro (In State) 0 0 0 0 0 0 0 0 0 0 0 0 0 Existing Large Hydro (Out State) 0 0 0 0 0 0 0 0 0 0 0 0 0 4-Hour Battery Storage (Li-Ion) 0 0 0 400 400 400 400 600 600 600 600 600 800 8-Hour Long Duration Storage 0 0 0 76 76 76 76 76 76 76 76 76 76 Flow Battery 0 0 0 0 0 0 0 0 0 0 0 0 0
Biomass 0 0 0 0 0 0 0 0 0 0 0 0 0
Geothermal 0 0 0 31 131 131 131 131 131 131 131 131 131 Solar PV 0 0 0 400 400 400 400 600 600 600 600 600 800
Wind (onshore) 0 0 0 0 0 0 0 310 310 310 510 510 510
Wind (Offshore) 0 0 0 0 0 0 0 0 0 0 170 170 170
Total 1,550 2,483 2,933 3,839 3,939 3,972 3,972 4,682 4,650 4,650 5,020 4,999 5,399 Agenda Page 42
18 Figure 6: CPA’s Contracted and Planned New Resource Build CPA’s mix of new resources is generally consistent with the 2021 PSP Portfolio. Overall, there are more new resources selected than the proportional share of the RSP, particularly for solar, wind, geothermal, and battery storage resources.
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19 Table 7: Comparison of the CPA Preferred Conforming Portfolio vs. CPA’s Load Share of the 2021 PSP Portfolio:
b. Preferred Conforming Portfolios
CPA is presenting one preferred Conforming Portfolio for the 25 MMT GHG target for Commission approval or certification. This 25 MMT case is reflective of the procurement objectives and preferences of CPA’s Board and local stakeholders. The CPA’s Conforming Portfolio is also consistent with each relevant statutory and administrative requirement stated in PU Code Section 454.52(a)(1), as follows:
A. Meet the greenhouse gas emissions reduction targets
The Preferred Conforming Portfolio achieves emission targets that are below the GHG emissions benchmarks set by the Commission, which are based on the GHG emission reduction targets set by the California Air Resources Board for the electricity sector. The results are illustrated in the table below:
Table 8: CPA Portfolio 2035 GHG Results
Metric 2030 GHG Emissions (MMT) 2035 GHG Emissions (MMT) Emissions Benchmark for CPA 1.049 0.848
CPA Portfolio Results 1.0462 0.845
CPA Proportional Share of the 25 MMT Proposed RSP (MW) CPA 25 MMT Capacity (MW) Difference RSP Share-CPA Plan) Resource 2024 2026 2030 2035 2024 2026 2030 2035 2024 2026 2030 2035 Large Hydro 875 873 883 881 500 500 - - 375 373 883 881 Imported Hydro 581 581 581 581 - - - - 581 581 581 581
Asset Controlling Supplier - - - - - - - - - - - -
Nuclear 701 249 249 249 - - - - 701 249 249 249
Biogas 75 75 77 78 - - - - 75 75 77 78
Biomass 159 168 174 173 - - - - 159 168 174 173
Geothermal 465 721 850 850 596 750 2,003 1,989 (131) (29) (1,153) (1,139) Small Hydro 208 208 208 208 99 99 81 21 109 109 127 187 Wind Resources
Wind Baseline California 849 849 849 849 668 664 651 427 181 185 198 422 Wind New PG&E 131 255 255 255 - - 226 226 131 255 29 29 Wind New SCE SDG&E 186 186 186 186 - - 287 287 186 186 (101) (101) Wind Pacific Northwest - 61 61 61 - - - - - 61 61 61
Wind Wyoming - - 441 441 - - - 449 - - 441 (8)
Wind New Mexico 41 77 548 548 843 841 1,670 1,670 (802) (764) (1,121) (1,121) Wind Offshore Morro Bay - 25 42 649 - - - 346 - 25 42 303 Wind Offshore Humboldt - - - 365 - - - 410 - - - (44)
Solar Resources
Solar Baseline California 1,920 1,919 1,917 1,916 1,881 1,816 1,707 1,353 39 103 210 563 Solar New PG&E 140 140 162 162 0 1,416 1,684 1,950 140 (1,276) (1,522) (1,789) Solar New SCE SDG&E 635 1,016 2,205 2,421 1,089 2,901 3,158 3,404 (454) (1,885) (953) (983) Solar Distributed 10 11 11 11 - - - - 10 11 11 11
Hybrid/Paired
Hybrid or Paired Solar and Battery 314 374 387 386 - - - - 314 374 387 386 Storage & DR
Shed DR 151 155 155 155 - - - - 151 155 155 155
Pumped Storage 93 102 142 142 - - - - 93 102 142 142
Battery Storage 2,125 2,390 3,550 4,588 1,172 3,375 4,165 4,963 953 (985) (615) (375) User-Specified Profiles
Storage Resource Custom Profile - - - - - - - - - - - - RPS Resource Custom Profile - - - - - - - - - - - -
GHG-free non-RPS Resource Custom Profile - - - - - - - - - - - - Coal
Coal - - - - - - - - - - - -
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20 B. Procure at least 60% eligible renewable energy resources CPA’s Preferred Conforming Portfolio would result in 100% of load being served by eligible renewable resources in 2030. This is 40 percentage points above the RPS requirement of 60% by 2030.
As illustrated in the graphs below, The Preferred Conforming Portfolio will achieve the statutory renewable energy procurement goal. The 25 MMT portfolio achieves and exceeds RPS compliance requirements for the entire study period.
Figure 7: 25 MMT RPS Compliance
C. Enable each electrical corporation to fulfill its obligation to serve its customers at just and reasonable rates
While this requirement does not apply to CPA as CPA is not an electrical corporation, CPA is committed to serving its customers at reasonable rates. In addition, CPA works to minimize rate volatility by constructing a balanced and conservatively hedged power supply portfolio, building significant financial reserves and minimizing rate changes when possible. Total system costs for the 25 MMT conforming portfolio is similar and comparable to CPA’s current average costs, as described further in Section E. The steady projected portfolio costs indicate that CPA ratepayers can expect their rates to receive increasingly clean electricity service at affordable and stable rates.
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21 D. Minimize impacts on ratepayers’ bills
CPA’s Preferred Conforming Portfolio meets the goal of minimizing bill impact on ratepayers by optimizing renewable and carbon-free energy procurement. The 25 MMT Conforming Portfolio identified the lowest cost, bulk power supply portfolio. The cost analysis studies only power supply components of serving retail load; as a CCA, the incumbent IOU is still responsible for transmission and distribution of the energy to the retail level. The cost of procuring the resources selected in the 25 MMT Conforming Portfolio is forecasted to increase CPA’s power supply costs at an average rate of 1.4% annually between 2023 and 2035. Additionally, CPA’s portfolios account for the RA benefits of IOU resources that its customers pay through the Cost Allocation Mechanism (CAM). The CPUC adopted the CAM to support the development of new generation resources to ensure electric reliability and to allow the costs and benefits of new generation to be shared by all benefiting customers in an IOU’s service territory.
E. Ensure system and local reliability on both a near-term and long-term basis, including meeting the near-term and forecast long-term resource adequacy requirements CPA’s Preferred Conforming Portfolio meets the requirement of ensuring system and local reliability. For system reliability, CPA used two metrics to assess if CPA’s portfolio maintains system reliability. The first method is evaluating how CPA’s portfolio meets RA capacity to comply with the state’s system RA requirement. The second is evaluating curtailment of intermittent resources. As described further in Section F, the results of Preferred Conforming Portfolio are reliable. For local reliability, CPA’s Preferred Conforming Portfolio places strong emphasis on developing new local capacity to meet the local procurement preference adopted by its Board. CPA’s Preferred Conforming Portfolio tracks closely with the resource mix of the Reference System Plan, ensuring that diverse resources are utilized to meet the grid’s reliability needs.
F. Ensure that at least 65% of RPS procurement is from long-term contracts As indicated in table below, CPA procures more than the required 65% long-term RPS contracting requirement. This is because CPA’s internal portfolio renewable target to meet its customers demand exceeds the California RPS targets for its managed retail sales.
Table 9: SB 350 Compliance, CPA Preferred Conforming Portfolio G. Strengthen the diversity, sustainability, and resilience of the bulk transmission and distribution systems, and local communities
Calendar Year 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 Retail Sales (MWhs) 10,649,290 10,803,705 10,901,820 11,015,379 11,087,483 11,154,570 11,248,740 11,321,003 11,397,823 11,466,833 RPS Requirement (MWhs) 3,700,628 3,943,352 4,169,946 4,846,767 5,100,242 5,577,285 5,849,345 6,113,342 6,382,781 6,880,100 (A) Annual RPS Targets % 35% 37% 38% 44% 46% 50% 52% 54% 56% 60% (B) 65% Requirement 65% 65% 65% 65% 65% 65% 65% 65% 65% 65% (A*B) Long Term Contracting Compliance Requirement 23% 24% 25% 29% 30% 33% 34% 35% 36% 39% RPS Compliance from Long Term Contracts 1,447,659 2,773,737 2,432,116 3,556,770 5,620,705 7,127,483 7,724,767 8,232,945 8,308,505 9,686,240 CPA RPS under LT Contract (% Load) 14% 26% 22% 32% 51% 64% 69% 73% 73% 84% CPA RPS Under LT Contract
Compliance Period Requirement
23% 61% 77%
25% 32% 37%
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22 CPA’s Conforming Portfolio relies on procurement from a variety of resource types as well as significant storage resources. CPA carefully evaluates the long-term generation load-matching and congestion risks of new resources and weighs its options in the context of its existing supply and net demand on an hourly basis for the full duration of any contract period. CPA is including both long-duration storage resources as well as conventional 4-hour battery storage in its portfolio currently because the PLEXOS modeling indicated that such resources reflect a cost optimal approach to meeting CPA’s load-resource balance. Also, CPA is actively pursuing long-duration storage through its 2022 Mid-Term Reliability Request for Offer (RFO), CPA’s competitive solicitation, pursuant to D. 21-06-035. CPA has also developed several customer programs to support clean energy and improve grid resilience, such as Power Response, CPA’s demand response program, and Power Ready, which is providing backup solar and storage systems for critical facilities in its service territory to be used in grid emergencies and outages.
H. Enhance distribution systems and demand-side energy management CPA’s Preferred Conforming Portfolio meets the requirement of enhancing demand-side management.
Based on CPA’s Local Programs for Clean Energy Future Strategic Plan, which was developed through a community outreach process and subsequent Board direction, CPA plans to deploy air pollution mitigation programs in Disadvantaged Communities (“DACs”) within its territory, in the following three strategic program areas: resiliency and grid management, building and transportation electrification, and local procurement of distributed energy resources. Details about these programs can be found in sections II.d.ii and III.b.
CPA actively supports EV charging infrastructure and distributed energy resource activities to meet its renewable energy goals. CPA is partnering with customers to utilize energy storage systems for demand response and/or reliability. In addition, CPA’s customer programs, such as Power Response and Peak Management Program incentivize commercial and public agency customers to reduce their energy consumption during periods of grid stress and elevated wholesale energy prices.
I. Minimize localized air pollutants and other greenhouse gas emissions, with early priority on disadvantaged communities
CPA Conforming Portfolio results in emissions lower than CPA’s assigned benchmark. CPA does not procure electricity directly from any natural gas or other fossil resource power plants. CPA’s Preferred Conforming Portfolio meets the requirement of minimizing localized air pollutants, with the emphasis on DACs. CPA’s portfolio relies primarily on renewable generation for its energy supply and would have low GHG and localized air pollutant emissions. As mentioned above, CPA also plans to deploy air pollution mitigation programs in its DACs to further reduce localized air pollution in its service territory.
CPA currently administers the Commission-funded Disadvantaged Community Green Tariff (DAC-GT) and Community Solar Green Tariff (CS-GT) programs to promote development of RPS-eligible projects located in DACs. These projects deliver renewable power to CPA’s customers, while improving air quality, providing economic benefits, and creating hundreds of jobs in the projects’ regions. Please refer to Section III.b below for further details.
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23 c. GHG Emissions Results
The 25 MMT Conforming Portfolio’s emissions, calculated using the CSP methodology from the CPUC’s GHG Calculator, are below the respective 2030 & 2035 GHG emissions benchmarks set by the CPUC, as illustrated in the table below:
Table 10: CPA’s Portfolio Emissions
Metric 2030 GHG Emissions (MMT) 2035 GHG Emissions (MMT) Emissions Benchmark for CPA 1.049 0.848
CPA Portfolio Results 1.042 0.845
CPA utilized a custom production profile in the CSP to account for short-term renewable energy purchases from existing resources in the 2024 and 2026 study years to meet its internal renewable energy demand procurement targets. These profiles were developed using solar and wind hourly profiles, assuming the renewable energy would be sourced 50% from wind and 50% for solar. d. Local Air Pollutant Minimization and Disadvantaged Communities i. Local Air Pollutants
Below is a summary of the NOx, PM2.5, and SO2 emissions associated with CPA’s Preferred Conforming Portfolio:
Table 11: Local Air Pollutants Estimate from CSP
The only contribution to air pollutants in CPA’s portfolio is from system power. As CPA continues to increase the portion of its portfolio under long-term contract with clean energy resources and bringing online more storage resources to minimize the emissions intensity of system power during net peak load hours, CPA will reduce its reliance on system power and its portfolio’s contribution to local air pollution. ii. Focus on Disadvantaged Communities
Per its Joint Powers Agreement, CPA intends to provide and manage its energy portfolio and products in a manner that promotes public health in areas impacted by energy production, including Disadvantaged Communities (DACs), as defined based on CalEPA’s CalEnviroScreen tool.
Emissions Total Unit 2024 2026 2030 2035
CO2 MMt/yr 1.33 1.14 1.04 0.85
PM2.5 tonnes/yr 36 26 35 28
SO2 tonnes/yr 4 3 3 3
NOx tonnes/yr 97 83 90 57
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24 Description of Disadvantaged Communities
Utilizing the CalEnviroScreen 4.0 dataset, CPA has determined that 36% of the 182 zip codes within its service territory either entirely or partially contain census tracts identified as Disadvantaged Communities. These communities approximately represent a total population of 892,160 ratepayers, or roughly 29% of CPA’s total number of customers.
The map below provides a visual representation of DAC census tracts within CPA’s service territory:
Figure 8: CPA Service Territory Map
The table below shows the specific zip codes within CPA service territory that contain DAC census tracts:
Table 12: DACs served by CPA, by member jurisdictions
Member Agencies DAC Zip Codes
Agoura Hills None
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25 Alhambra 91801, 91803
Arcadia None
Beverly Hills None
Calabasas None
Camarillo None
Carson 90502, 90745, 90746, 90810
Claremont None
Culver City 90066, 90232
Downey 90240, 90241, 90242
Hawaiian Gardens 90716
Hawthorne 90250
Los Angeles County
(unincorporated)
90001, 90002, 90022, 90023, 90043, 90044, 90047, 90059, 90061, 90063, 90220, 90221, 90222, 90248, 90250, 90255, 90262, 90270, 90292, 90303, 90304, 90502, 90601, 90605, 90606, 90640, 90660, 90670, 90810, 91016, 91342, 91608, 91702, 91732, 91733, 91744, 91745, 91746, 91748, 91754, 91767, 91768, 91770, 91776, 93535, 93543, 93550, 93552
Malibu None
Manhattan Beach None
Moorpark None
Ojai None
Oxnard 93030
Paramount 90723
Redondo Beach None
Rolling Hills Estates None
Santa Monica 90401, 90404
Sierra Madre None
Simi Valley None
South Pasadena None
Temple City None
Thousand Oaks None
Ventura 93001
Ventura County
(unincorporated)
93001, 93033, 93036
West Hollywood None
Westlake Village None
Whittier 90601, 90602, 90606
Procurement Considerations Related to Disadvantaged Communities In developing its IRP, CPA carefully considered the impact of its resource procurement on DACs. The CPA portfolio does not include energy contracts with gas generators, including those gas facilities located within or adjacent to DACs. The portfolio minimizes the use of unspecified CAISO system power by increasing its long-term contracting with clean energy resources over time, reducing its potential indirect reliance on gas generators that have an impact on DACs.
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26 One of CPA’s long-term program objectives to minimize local air pollutants is to provide to its customers clean energy through the renewable and GHG-free power procurement, and CPA intends to contract exclusively with renewable or GHG-free generation resources, pursuant to its program objective and SB 100 mandate. To promote cost savings and risk management for our ratepayers, CPA will continue to rely on some unspecified CAISO system power for short-term energy needs beyond its long-term contracts. In 2023, CPA’s generation portfolio will achieve an 80 percent GHG-free and 77 percent renewable energy mix, resulting in an energy supply that possesses both a greater renewable content and a lower GHG emission rate than that of the incumbent utility. CPA’s long-term energy procurement policy is not expected to negatively impact local air quality.
Utilizing the U.S. EPA’s Facility Level Information on Greenhouse Gases Tool (FLIGHT) data, CPA has identified six power plants within its territory that are classified as large emitters, two of which are located within a zip code containing Disadvantaged Communities. To the extent practical, CPA is committed to identifying opportunities to support the replacement of retired facilities with renewable resources to reduce the pollution burden in these communities through its procurement activities.
Pursuant to CPUC D.18-06-027, CPA obtained the Commission’s approval to administer the DAC/CS-GT programs, collectively known as the CPA Power Share Program, in 2020. At the time of this filing, CPA has contracted with the following new build solar projects located within DACs. This program increases the number of clean energy projects located in DACs, not only within CPA’s service territory, but statewide:
Table 13: CPA Contracted DAC-GT Resources
Project Size Location Program
Radiant 3.0 MW Minneola, CA DAC-GT
Dominguez 0.96 MW Carson, CA DAC-GT
El Segundo 0.64 MW Hawthorne, CA DAC-GT
Wilmington 1 1.8 MW Carson, CA DAC-GT
Wilmington 2 0.6 MW Carson, CA DAC-GT
Workman 1.92 MW Whittier, CA DAC-GT
DAC Outreach
The development of the IRP was based on input from disadvantaged community representatives, both from CPA’s Community Advisory Committee3 and based on CPA’s Local Programs for Clean Energy Future Strategic Plan4, which was developed through a community outreach process and subsequent 3 Clean Power Alliance has a dedicated Community Advisory Committee (CAC) comprised of customers who are leaders in their communities to advise our Board of Directors on policies, programs, and planning, while also serving as customer advocates.
Our 15-member CAC represents 7 sub-regions of our service territory, including disadvantaged community customers. 4 See CPA website for further information: https://cleanpoweralliance.org/localprogramsplan/ Agenda Page 51
27 Board direction. CPA plans to deploy air pollution mitigation programs in Disadvantaged Communities within its territory, in the following three strategic program areas:
• Resiliency and grid management, including clean back-up power for essential facilities, demand response from behind the meter energy storage, and peak management pricing • Electrification, including incentives for public electric vehicle charging and building electrification codes
• Local procurement, including the DAC/CS-GT Power Share program Prior to finalizing the IRP, CPA presented the analysis and action plan to its Community Advisory Committee and received positive feedback from committee members, some of them representing disadvantaged communities served by CPA. CPA plans to follow up with its Community Advisory Committee to present the final results to inform the development of its future IRPs, as well as its procurement and program design strategies.
In addition, CPA partners with 180 community-based organizations (CBOs) on a range of outreach efforts, including targeted outreach to disadvantaged communities. Through regular dialogue with our communities, CPA’s resource planning and procurement strategies, rate and product offerings, and customer program designs are informed by the feedback we receive from community members and organizations. All these activities are factored in the IRP development to inform CPA’s organization-wide strategy to better serve our customers, with a special focus on improving air quality and access to clean energy in disadvantaged communities.
e. Cost and Rate Analysis
CPA’s Preferred Conforming Portfolio achieves results and performance characteristics consistent with the Section 454.52(a)(1)(D) goal of minimizing the impact of planned procurement on ratepayers’ bills.
CPA’s portfolio costs and expected impacts to electricity rates for the 25 MMT preferred compliance portfolio is depicted below. A full description of the cost components follows that define each discrete component.
As discussed in Section II. Study Design, CPA’s portfolio was optimized around RPS and GHG-free regulatory requirements and added or removed resources to arrive at or just below the 2035 25 MMT GHG target. As a result, most of the CPA’s portfolio cost in the early years is driven by the underlying changes in the California market. In the final years of the study horizon, the expansion plan is building additional onshore and offshore wind resources to achieve its proportional share of the GHG MMT target. Below is the chart of costs considered in CPA’s portfolio, followed by detailed explanation of each factor.
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28 Figure 9: CPA 25 MMT Portfolio Costs ($,000)
Market Purchases: The Preferred Conforming Portfolio starts with significant amounts of market purchases in the early years of the study period. Market purchases continue to diminish over the study horizon as CPA enters into long-term contracts. Given the portfolio mix of CPA, there is early reliance on short-term contract purchases. Over time, CPA becomes less reliant on short-term purchases as long-term contracts with new candidate resources increase, providing significant amount of generation.
New Resource Addition Costs: As CPA begins to build new resources within the portfolio, the cost mix of the portfolio begins to shift and becomes largely driven by the capital and fixed O&M costs for long term capacity selected by the optimization routine.
Capacity Market Costs: Capacity market costs serve as a representation for the cost of RA products to meet reliability requirements. Capacity market contract costs were based on CPA’s RA price forecasts over the duration of the study period. RA prices were forecasted to be driven by BESS capital costs. CPA assumed that RA prices will decline due to battery deployment and reductions in BESS capital costs, with batteries increasingly providing RA. In the later years, RA prices will rise as the required storage duration for full ELCC increases at higher battery penetrations, offsetting capital cost reductions. The contribution to total system costs from the reliability products is steady over the study horizon.
CPA Short-Term Renewable Energy Credit (ST REC) Costs: REC purchases serve as a representation for the cost of short-tern renewable energy products from existing resources that CPA will need to meet internal RPS and GHG-free targets. REC price forecasts were derived from CPA internal market forecasts and were assumed to fluctuate depending on available renewable generation in California.
PCIA VAMO Costs: Pursuant to the Voluntary Allocation Market Offer (VAMO) framework in the PCIA rulemaking (R.17-06-026), the CPA’s Board of Directors approved electing 50% of the Long-Term Voluntary Allocations from SCE’s PCIA-eligible RPS energy portfolio. CPA formally made the Long-Term Agenda Page 53
29 Voluntary Allocation election on May 24, 2022, and these resources are included in the Preferred Conforming Portfolio. CPA pays for the PCIA VAMO resources at the RPS Market-Price Benchmark, and CPA has assumed the same short-term REC price forecast for these resources, as described in the paragraph above.
Total System Cost: Overall, the transition from relying on market purchases to serving energy needs through owned and contracted resources does not have a major impact on the cost to serve load on a $/MWh basis. The range of cost to serve load on a $/MWh basis is within $63-$85/MWh over the entire study horizon. These costs do not reflect CPA’s non-energy procurement costs (e.g., data and customer management, overhead, etc. are not included in this analysis).
The portfolio cost components include:
• New Resource Addition Costs: Includes capital and fixed O&M costs for long term capacity selected by the optimization analysis
• Contract Costs: Reflects total cost for existing PPAs, as provided by CPA • Capacity Market Costs: Existing and future RA capacity purchase needs to meet an overall 14% planning reserve margin requirement
• Short-term REC Costs: Reflects CPA-developed REC market price forecast for short-term renewable energy contracts with existing resources
• PCIA VAMO Costs: Reflects CPA-developed REC market price forecast for PCIA voluntary RPS allocation from SCE
• Market Purchases: Reflects spot market Purchases
• Market Sales: Reflects spot market Sales
• NPV: Discount Rate of 8% is applied
The Preferred Conforming Portfolio identified the lowest cost, bulk power supply portfolio to meet the 25 MMT GHG target as well as CPA’s procurement goals and is reasonable from a cost perspective. The cost analysis studies only power supply components of serving retail load; as a CCA, the incumbent IOU is still responsible for transmission and distribution of the energy to the retail level. The cost of procuring the resources selected in the 25 MMT Conforming Portfolio reflects a manageable increase CPA’s power supply costs at an average rate of 1.4% annually between 2023 and 2035. The range of costs declines in early years and begins to rise steadily through the forecast horizon as CPA expands its portfolio. This is because CPA relies more heavily on short-term capacity and energy market purchases in early years, and more on candidate resources with a falling cost projection in later years. CPA’s portfolio total costs decline overtime specifically because of the falling cost of solar, wind, and battery resources over time. Additionally, CPA’s portfolio accounts for the costs of more short-term renewable resources in early years that CPA customers already pay above market costs for through the PCIA. CPA’s portfolio total costs increase in the period starting in 2030 and beyond with a shift to more expensive technologies, such as offshore wind. CPA also recognizes that future resource costs are highly uncertain, and technology advancement can happen unexpectedly; CPA’s procurement cycle is designed to take advantage of technology and cost improvements by adding new resource commitments incrementally over time.
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30 f. System Reliability Analysis
CPA’s Preferred Conforming Portfolio meets its system reliability needs using a combination of contracted resources, planned new build resources, and existing resources:
Table 14: Load and Resource Table from RDT
Figure 10: CPA Capacity by Contract Status
In addition, CPA used two metrics to assess if CPA’s portfolio maintains system reliability. The first is evaluating the extent to which CPA’s portfolio relies on short-term RA purchases from existing resources to comply with the state’s system RA requirement. The second is evaluating curtailment of intermittent resources.
Resource Adequacy (RA)
CPA evaluated system reliability by assessing its open System RA position compared to its load share of total system resources in the respective RSP, net of its contracted resources and coal and nuclear resources, for which CPA does not contract. Including a 14% reserve margin over CPA’s forecast peak load and the projected declines in ELCC for clean energy resources, the largest anticipated open System RA position is still within the CPA’s load share of existing system resources in the RSP, as shown in the 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 LSE reliability need (MW) 2,690 2,755 2,825 2,749 2,674 2,738 2,793 2,711 2,616 2,528 2,441 2,363 ELCC by contract status (effective MW)
Online 2,346 1,880 1,471 1,361 1,311 1,339 1,077 1,144 1,196 1,149 1,220 1,206 Development 320 836 840 797 785 808 831 749 668 588 507 427 Review - - - - - - - - - - - -
PlannedExisting - - - 92 93 92 91 92 93 93 94 95
PlannedNew - 16 491 470 449 464 762 691 620 654 573 584 BTM PV 24 24 23 30 37 35 32 36 39 43 47 51
LSE total supply (effective MW) 2,690 2,755 2,825 2,749 2,674 2,738 2,793 2,711 2,616 2,528 2,441 2,363 Net capacity position (+ve = excess, -ve = shortfall) (effective MW) - - - - - - - - - - - - 0 500
1,000
1,500
2,000
2,500
3,000
2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 MW
BTM PV
PlannedNew
PlannedExisting
Review
Development
Online
LSE reliability need (MW)
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31 Table below. As long as the System RA attributes in excess of other LSE load shares are not withheld from the market, the system as a whole should have adequate resources to accommodate CPA’s portfolio.
Table 15: CPA RA Assessment (Preferred Conforming Portfolio) Year LSE Reliability Need System RA need Met
with Short-Term
Purchases
CPA Load Share of
System Resources
(ELCC Adjusted)
Short-term Purchases
Exceeding System
Share
2024 2,690 1,451 2,347 No
2026 2,825 776 2,463 No
2030 2,793 461 2,162 No
2035 2,363 793 2,044 No
Curtailment
CPA evaluated curtailment as a metric for reliability using the PLEXOS model. 5 CPA’s 25 MMT case
demonstrates less than 0.4% of supply curtailed in year 2035. There are minimal curtailments expected for all other years. The simulation results show curtailments mostly during the solar hours. There are minimal or no curtailments of renewables during non-solar hours. This is because of a large amount of battery storage and paired of solar and storage buildouts that reduce renewable curtailments. Most of the curtailments happen after the study horizon (post 2035), when there is greater penetration of renewable generation in the portfolio and in the California market. A summary of curtailment as a percentage of load is provided in the table below.
Table 16: Curtailment as a Percentage of Load by Case
g. High Electrification Planning
As part of its scenario planning, CPA developed a resource needs analysis under a high load and high electrification scenario. For this scenario, CPA determined that it would need to procure additional new renewable resources to meet its RA, RPS, and Greenhouse Gas Reduction Targets, specifically additional solar generation. There is no locational-specific information for these generic resources, although CPA expects to procure these resources within CAISO, and likely southern California.
Table 17: Additional Resource Needs for the High Electrification Scenario Resource
Type
MWs Annual
GWh
2035 GHG
target
Transmission Zone Substation/Bus Alternative
location
Note
Solar PV 315 973 25 MMT Solar New SCE SDG&E N/A N/A N/A 5 CPA believes that the curtailment estimate from the PLEXOS is more accurate than the CSP tool, because the CSP is a static tool that does not reflect actual market dispatches of resources.
CPA 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 25 MMT 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.4% Agenda Page 56
32 h. Existing Resource Planning
Beyond its long-term contracting for build resources CPA’s portfolio also relies on existing resources to meet its renewable energy demand and RA demand.
Renewable Energy Resources
In addition to long-term contracts with new build RPS-eligible resources, CPA also expects to meet its renewable energy demand using PCIA VAMO resources and using short-term contracts for renewable energy from existing RPS resources. PCIA VAMO resources are included in the CSP tool based on the portfolio resource mix provided by SCE and reflect only the 50% election of long-term contracts that were approved by CPA’s Board to date. The short-term renewable energy contracts are included in the CSP tool for the 2024 and 2026 study years, using a custom profile and assuming a mix of 50% wind and 50% solar resources. These volumes are consistent with the short-term renewable energy purchases that CPA has historically made to meet its renewable energy demand, and CPA is also considering short-term volume that will be made available to purchase from SCE’s PCIA VAMO Market offer process.
RA Resources
As described in detail in Section III.f, CPA plans to meet some of its RA requirements in the future with short-term RA contracts with existing resources. As part of its system reliability analysis, CPA determined that it is not relying on more than its load-share of statewide RA resources.
CPA believes that some reliance on existing resources to meet its portfolio demand is appropriate because it allows CPA to meet its RA requirements cost effectively, and it ensures that existing RA resources in the market are not stranded. CPA may increase its proportion of new resources to meet RA requirements in the future if it deems that new resources will result in a more cost-effective reliable portfolio.
Comparison to the 2020 38 MMT Preferred Conforming Portfolio In comparison to CPA’s 2020 38 MMT Preferred Conforming Portfolio, CPA’s 2035 25 MMT portfolio in the 2022 IRP has selected significantly less hydrogeneration resources to acknowledge the increasing risk associated with in-state and imported hydro generation due to severe drought brought on by climate change. In shifting away from hydrogeneration procurement, CPA’s 2035 25 MMT portfolio has selected more onshore wind, and in later planning years, more offshore wind, as those require longer planning horizon would need to mitigate the risks associated with higher cost and transmission capability to realize. CPA’s 2022 IRP has also selected less solar due to its higher saturation on the grid. i. Hydro Generation Risk Management
CPA’s portfolio has limited exposure to in-state drought. CPA’s portfolio includes only a small amount of RPS hydro currently under contract, the 11.95 MW Isabella facility and the 20.09 MW Kaweah facility, which are existing resources and would be impacted by changing rainfall/snowpack. These resources Agenda Page 57
33 make up less than 1% of CPA’s overall load, and therefore pose minimal risk. They are expected to have a negligeable impact on costs, GHG emissions and reliability. While having a small overall impact on CPA’s portfolio and expected costs, there are four distinct risks and potential impacts associated with these resources related to drought:
• Energy. CPA expects to know ahead of the impacted year what the impact of a drought will be on production. Any energy shortfall will be addressed through CAISO spot market purchases. • Capacity. CPA’s small-scale hydro resources represent only 1% of total capacity for all CPA’s contracted resources and therefore capacity risk for hydro generation is negligeable • RPS. CPA expects to achieve and exceed RPS compliance requirements for the 2023-2035 study period, which means any shortfall of RPS due to hydro generation will likely not affect the RPS compliance for CPA.
• GHG. A shortfall of energy will reduce the amount of carbon-free energy in CPA’s portfolio.
However, hydro generation’s impact on CPA’s GHG emissions is small, and CPA expects to be able to make up for any shortfall with short-term RECs purchases.
In developing its conforming portfolio, CPA took several steps to manage the risk of reduced hydropower availability due to in-state or out-of-state drought. Compared to CPA’s 2020 IRP which included in-state and out-of-state large hydro in its 38 and 46 MMT preferred portfolios, CPA’s 2022 IRP does not include is not including any incremental hydro generation beyond what is already contracted to date6 as a means to achieve CPA’s 2035 GHG benchmark emissions targets for the 25MMT conforming portfolio, reducing CPA’s dependence on this technology type in the case of a WECC-wide drought event:
Table 18: Comparison of Planned Hydro Resources in CPA’s 2022 IRP vs. the 2020 IRP Planned Hydro Resources (MW) 2024 2026 2030 2035
2022 IRP
Existing Large Hydro (In State) 0 0 0 0
Existing Large Hydro (OOS) 0 0 0 0
2020 IRP (38 MMT Case)
Existing Large Hydro (In State) 90 120 300 N/A
Existing Large Hydro (OOS) 90 120 290 N/A
In section II.b.a, CPA provided a comparison of the 2021 PSP with CPA’s 2022 IRP 2035 25 MMT conforming portfolio. In comparison, CPA’s 2035 25 MMT conforming portfolio has selected significantly less hydrogeneration than its proportional share of 2021 PSP hydrogeneration resources.
However, CPA recognizes that a drought could reduce the delivery of carbon-free energy from contracted hydro resources and therefore put CPA at risk of buying short-term energy purchases at high prices. To mitigate this risk, CPA plans to increase the amount of solar PV and wind in its portfolio and 6 CPA’s CSP includes existing hydro resources in the 2024 and 2026 study years. These are already under contract.
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34 thereby reduce expected emissions to less than the benchmark GHG amounts. Higher levels of solar PV and wind in CPA’s portfolio may also help reduce the overall costs of electricity for CPA’s customers.
CPA’s hedging of supply risk is focused on the forward 5-year period and includes securing a variety of resources to ensure delivery at stable costs of all the attributes needed in CPA’s portfolio, including energy, RA, GHG emissions, and RPS requirements. Due to their short-term nature, hedging decisions are not directly part of the IRP or able to address hydro delivery risk towards the end of the forecast period. However, if CPA’s carbon goals are deemed to be at risk, the hedging policy will seek to minimize that risk by procuring additional capacity or energy from carbon-free resources up to 5 years in advance. j. Long-Duration Storage Planning
In response to its procurement requirements under D.21-06-035, CPA has issued several RFOs for long-duration storage resources, with the capability to discharge at full capacity for 8 hours or longer. The first solicitation was CPA’s 2021 Mid-Term Reliability RFO, with bids due in November 2021. Although CPA shortlisted and entered into negotiations with several long-duration storage projects, it was not successful in contracting for resources from this RFO. In June 2022, CPA issued its 2022 Mid-Term Reliability RFO, with bids due in September 2022. CPA received responses from several entities representing chemical and thermal long-duration storage technologies, including lithium-ion batteries, flow batteries, and compressed air storage technologies. CPA will be considering the information available through the RFO and will be evaluating the economics of such projects. This evaluation is expected to lead to PPA negotiations with shortlisted bidders aimed at bringing long duration storage projects online by 2026.
CPA anticipates it will procure at least 75.4 MW of long duration storage online by 2026, as required by D.21-06-035 and reflected in the Preferred Conforming Portfolio. CPA’s PLEXOS modeling did not select any additional long-duration storages candidate resources for its portfolio beyond what is required for D.21-06-035 compliance. The benefits of including long-duration storage in the portfolio mix include meeting CPA’s regulatory compliance and supporting overall grid reliability needs. The risks of including long-duration storage in the portfolio mix is potentially adding technology risk (if the long-duration storage technology is nascent) as well as increased costs for customers to meet storage needs that could otherwise be met with lower-cost storage configurations. k. Clean Firm Power Planning
CPA currently contracts for two existing clean firm power resources, the 14 MW Heber South geothermal plant and a 50 MW portion of the Geysers geothermal facility. Pursuant to D.21-06-035, CPA is required to procure 59 MW of incremental clean firm power NQC. In Fall 2021, CPA ran its 2021 Mid-Term Reliability RFO, from which it contracted for the 33 MW Cape Station geothermal facility in Utah, which is currently under development. CPA will require 33 MW of MIC at IPP in order to count the resource towards CPA’s RA requirements.
Agenda Page 59
35 Beyond these contracted resources, CPA’s Preferred Conforming Portfolio includes 30.6 MW of additional incremental clean firm power resources to reflect the remaining procurement CPA will conduct to meet its D.21-06-035 requirements. These resources may be located within CAISO or outside of CAISO, however, specific MIC or transmission upgrades are not yet known since specific resources have not yet been identified. In addition, CPA has included 100 MW of additional planned contracting with existing geothermal resources starting in 2027, which is under negotiation at the time of this filing.
The benefits of including clean firm power resources in the portfolio mix include meeting CPA’s regulatory compliance and supporting overall grid reliability needs. The risks of including clean firm power resources in the portfolio mix is potentially adding curtailment risk from baseload, non-dispatchable resources as well as increased costs for customers to meet renewable energy needs that could otherwise be met with lower-cost, more flexible technologies. l. Out-of-State Wind Planning
CPA has already contracted for 300 MW of out-of-state (“OOS”) wind from its Mohave Wind project located in Arizona. For its preferred portfolio, the PLEXOS model selected some new onshore wind for the study period. CPA is actively exploring new wind projects for procurement, including both in-state and out-of-state wind resources. OOS wind can offer several advantages over in-state wind.
Specifically, it generally offers higher capacity factors than wind resources available in California. It also offers a complementary generation profile to the solar resources, and it is well suited to match CAISO’s evening resource needs. These advantages can make OOS wind an attractive renewable resource.
However, the higher cost and risk associated with interconnection is a concern.
Given the saturation of wind resources within CAISO, CPA expects that a significant portion of new wind resources will be developed out-of-state. CPA’s onshore candidate resources include 105 MW in Northern California wind, 105 MW in Southern California, 200 MW in New Mexico, and 100 MW in Wyoming. These geographic locations were selected to be consistent with the new transmission projects identified in the CAISO 2021-2022 Transmission Planning Process, as shown below.
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36 Figure 11: Proposed Out-of-State Transmission Projects from the CAISO 2021-2022 Transmission Planning Process7
For the candidate resources in New Mexico and Wyoming, CPA understands that new transmission projects will be needed to connect significant quantities of OOS wind to the CAISO grid to achieve the statewide GHG reductions associated with the 25 MMT Reference System Plan. These transmission projects require significant lead-times, therefore, CPA has not included OOS Wind candidate resources in its preferred Conforming Portfolio until 2030. CPA is open to purchases of such resources and will evaluate offers it receives during its regular procurement process. m. Offshore Wind Planning
AB 525 directed the CEC to evaluate and quantify the maximum feasible capacity of offshore wind and set a statewide goal for procurement. The latest CEC report showed that between 3 to 5 GW of offshore wind could be procured by 2030, and California should be able to bring online 25 GW of offshore wind by 2045. D.22-02-004 further prescribed a process to explore the potential of offshore wind, which has recently culminated in sensitivity portfolios for TPP that force in offshore wind resources that the CAISO 7 From CAISO’s White Paper - Accessing Out-of-State Wind Resources to meet California Resource Adequacy Requirements, June 20, 2022
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37 will be examining once the portfolios are adopted. CPA is encouraged that the Commission as well as other energy agencies are taking steps to conduct long-term transmission planning focused on offshore wind, which is an important factor for bringing online a new resource type to the California energy market.
CPA acknowledges that there is a vast amount of offshore wind potential off the Pacific Coast. However, the development of these resources is challenged by the depth of sea floor (which would necessitate floating applications) and the lack of transmissions to areas with the best wind conditions. Although significant uncertainty exists about the viability of offshore wind in California, CPA has included both onshore and offshore wind in the IRP. CPA’s PLEXOS modeling identified offshore wind as a potentially beneficial resource to come online beginning in 2033 due to its higher capacity factor and energy delivery profile, which is complementary to solar. While offshore wind is an intermittent resource, its daily availability profile matches CPA’s load much better than solar and it shows less seasonal variability than solar. At this time, CPA does not have a position on which geographic area that offshore wind will be viable, and therefore has assumed 50% to be in the Central Coast and 50% to be in the North Coast.
Assuming it becomes both technologically viable and cost effective, offshore wind, with its attractive wind generation profiles, may contribute to California achieving its 100% zero carbon goal by 2045. n. Transmission Planning
CPA has a number of contracted resources that are contingent on interconnection upgrades, as summarized below:
Table 19: CPA Contracted Resources Requiring Interconnection Upgrades Facility Name Technology
Type MW Location COD
Network
Upgrades
Milestone
Azalea Solar + Storage 60 MW Solar /
38 MW Storage Kern County, CA 12/31/2024 Expected May 2024 Chalan Solar + Storage
64.9 MW Solar
/ 25 MW
Storage
Kern County, CA 12/31/2024 Expected
12/1/2023
Rexford Solar + Storage
300 MW Solar /
180 MW
Storage
Tulare, CA 12/31/2024 Expected
December 2024
Daggett Solar + Storage
123 MW Solar /
61.5 MW
Storage
San Bernardino
County, CA 12/01/2023 Expected April 15,
2023
Estrella Solar + Storage 56 MW Solar /
28 MW Storage
Los Angeles
County, CA 12/31/2023 Expected 11/30/2022
Daggett Solar
Power 2 Solar + Storage 52 MW Solar / 65 MW Storage
San Bernardino
County, CA 12/19/2023 Expected 12/09/2022
Arica Solar + Storage
93.5 MW Solar
/ 71 MW
Storage
Riverside County,
CA 06/01/2024 Expected
06/20/2023
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38 Desert
Quartzite Solar + Storage
300 MW Solar /
150 MW
Storage
Blythe, CA 03/01/2025 Expected
07/15/2024
Cape Station Geothermal 33 MW Beaver County,
UT 06/01/2028 Expected06/01/2028
Prologis –
Dominguez
Distributed
Solar 0.96 MW Carson, CA 12/30/2023 Expected 10/01/2023 Prologis – El
Segundo
Distributed
Solar 0.64 MW Hawthorne, CA 12/30/2023 Expected 10/01/2023 Prologis –
Wilmington 1
Distributed
Solar 1.8 MW Carson, CA 12/30/2023 Expected 10/01/2023
Prologis –
Wilmington 2
Distributed
Solar 0.6 MW Carson, CA 12/30/2023 Expected 10/01/2023
Prologis -
Workman
Distributed
Solar 1.92 MW Whittier, CA 12/30/2023 Expected 10/01/2023 For the generic new candidate resources, the Preferred Conforming Portfolio reflects CPA’s best estimate for new resource siting, based on resource availability and transmission projects identified by CAISO. CPA does not have specific siting (i.e., busbar mapping level) information for the generic new candidate resources. For new resources planned within CAISO, CPA is assuming that the locations align with current transmission systems with existing capability or upgrades currently under construction or approved by the CAISO board. However, depending on what resources are made available to CPA to meet its procurement targets, additional new transmission upgrades may be required.
CPA’s portfolio identifies new onshore wind resources located outside of CAISO and expects that new transmission projects may be required to deliver that energy into California. However, these new transmission projects are consistent with the CAISO’s 2021-2022 Transmission Plan.
CPA will continue to monitor the CAISO’s Transmission Planning Process and the status of different transmission projects as it develops new resources for its Preferred Conforming Portfolio.
III. Action Plan
a. Proposed Procurement Activities and Potential Barriers i. Resources to meet D.19-11-016 procurement requirements CPA has met and exceeded its needed procurement to meet D.19-11-016 2021, 2022, and 2023 targets with resources that have already come online:
Table 20: CPA D.19-11-016 Compliance Position
2021 2022 2023
Total D.19-11-016 Requirement (Cumulative) 98.5 147.7 196.9 Agenda Page 63
39 Compliance Resources Online Date 2021 2022 2023
Voyager Wind II 12/28/2018 3.2 3.2 2.36
White Hills 12/15/2020 39.38 39.38 39.38
High Desert Solar + Storage 12/8/20218 64 60.2 58
Sanborn Storage 11/1/20219 100.0 100.0 100.0
Arlington Solar (100 MW) 3/21/2022 14 11.1
Luna Storage 7/30/2022 100.0 100.0
Total Resources (NQC) 206.6 316.8 310.8
Because the requirements have been met and exceeded, no additional procurement related to D.19-11- 016 is planned and no barriers have been identified.
ii. Resources to meet D.21-06-035 procurement requirements, including:
CPA procurement obligation for D.21-06-035 is summarized below, for a total of 679 MW (in September NQC):
Table 21: CPA D.21-06-035 Procurement Obligation
2023 2024 2025 2026
(LLT Resources)
Minimum
Zero-Emitting
Capacity by 2025
Total
118 354 89 118 148 679
CPA’s procurement plans related to each of the D.21-06-035 categories is described in the following sections A through D.
a. 1,000 MW of firm zero-emitting resource requirements Pursuant to D.21-06-035, CPA is required to procure 59 MW of firm zero-emitting resources. In Fall 2021, CPA ran its 2021 Mid-Term Reliability RFO, from which it contracted for the 33 MW Cape Station geothermal facility in Utah, which is currently under development. Below is a table summarizing CPA’s outstanding procurement requirement for zero-emitting resources:
Table 22: CPA D.21-06-035 Compliance Position, Zero-Emitting Resources September NQC MW
Zero-Emitting Resource Requirement 59.0
CPA Contracted Resources 30.6
Remaining Requirement 28.4
8 The contracted COD date for High Desert Solar + Storage was August 1, 2021. The project was delayed several months due to force majeure, as reported to the CPUC via CPA’s IRP Data Request submissions. 9 The contracted COD date for Sanborn was August 1, 2021. The project was delayed several months due to permitting delays and vandalism, as reported to the CPUC via CPA’s IRP Data Request submissions.
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40 In August 2022, CPA launched its 2022 Mid-Term Reliability RFO to procure additional resources needed to fully contract for its D. 21-06-035 remaining obligations. This RFO is underway, and CPA anticipates executing contracts in early 2023. CPA intends to fill its remaining requirement for zero-emitting resources through this RFO as well as bilateral negotiations that CPA has underway at the time of this filing. These candidate resources are reflected in CPA’s plan. b. 1,000 MW of long-duration storage resource requirements Pursuant to D.21-06-035, CPA is required to procure 59 MW of long-duration storage resources. In Fall 2021, CPA ran its 2021 Mid-Term Reliability RFO and despite entering into negotiations with several developers, was unable to secure any long-durations storage contracts. These negotiations fell through due the unprecedented challenges faced by storage developers in 2022, including significant disruptions to commodity markets and supply chains resulting from the COVID-19 pandemic and the Ukraine War.
Below is a table summarizing CPA’s outstanding procurement requirement for long-duration resources:
Table 23: CPA D.21-06-035 Compliance Position, Long-Duration Storage Resources September NQC MW
Long-Duration Resource Requirement 59.0
CPA Contracted Resources 0.0
Remaining Requirement 59.0
CPA expects to procure all its remaining requirements for long-duration storage from its 2022 Mid-Term Reliability RFO, currently underway. These candidate resources are reflected in CPA’s plan. c. 2,500 MW of zero-emissions generation, generation paired with storage, or demand response resource requirements
To date, CPA has contracted with the following resources that qualify as incremental D. 21-06-035 resources, which are all renewable generation paired with storage:
Table 24: CPA Contracted D.21-06-035 Zero-Emissions Generation Resources In summary, CPA has met its requirements towards the 2,500 MW of zero-emissions generation requirement by 2025:
Resource Commercial Operation Date
Nameplate Renewable
MW
Nameplate Storage
MW
Incremental Zero-Emitting Capacity MW
Resurgence Solar plus Storage 06/01/2023 48 40 32
Daggett 3 Solar plus Storage 12/01/2023 123 61.5 49.2
Daggett 2 Solar plus Storage 12/19/2023 65 52 41.6
Estrella Solar plus Storage 12/31/2023 56 28 22.4
Azalea Solar plus Storage 12/31/2024 60 38 30.4
Chalan Solar plus Storage 12/31/2024 65 65 52
Arica Solar plus Storage 06/01/2024 93.5 71 56.8
Rexford Solar plus Storage 12/31/2024 300 240 192
Desert Quartzite Solar plus Storage 03/01/2025 300 150 120 Total 1,110.5 745.5 596.4
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41 Table 25: CPA D.21-06-035 Compliance Position, Zero-Emissions Generation September NQC MW
Zero-Emissions Generation Resource Requirement 148.0
CPA Contracted Resources 596.4
Remaining Requirement 0
CPA does not plan to do any additional procurement with respect to this requirement. However, CPA will be doing additional procurement related to its D. 21-06-035 remaining obligations, which may include addition zero-emissions generation resources, as described in the following section. d. All other procurement requirements
To date, CPA has contracted for the following resources in meeting its D.21-06-035 2023-2025 procurement obligations:
Table 26: CPA Other Contracted D.21-06-035 Resources
Below is summary of the annual cumulative compliance obligations and CPA’s net compliance position using the resource counting methodology adopted in the Decision:
Table 27: CPA D.21-06-035 Compliance Position, General Procurement 8/1/2023 6/1/2024 6/1/2025
D.21-06-035 General Procurement Need 118.0 472.0 561.0
CPA Contracted Resources 118.0 368.0 730.1
Compliance +Short / (Long) 0.0 104.0 (169.1)
CPA will require further procurement of resources coming online by June 1, 2024. In August 2022, CPA launched its 2022 Mid-Term Reliability RFO to procure these additional. This RFO is underway, and CPA anticipates executing contracts in early 2023.
iii. Offshore wind
CPA’s Preferred Conforming Portfolio does not include new wind resources until 2033. Therefore, CPA plans to run competitive solicitations for these resources in the 2027-2030 timeframe. The greatest barrier to offshore wind procurement is cost and technological viability. Offshore wind technology is nascent and expected to be expensive until it becomes commercially viable. CPA will determine Resource Commercial Operation Date
Nameplate Renewable
MW
Nameplate Storage
MW Tranche 1 NQC Tranche 2 NQC Tranche 3 NQC
Arlington Storage Online 0 132 115.6
Resurgence Solar plus Storage 06/01/2023 48 40 38.52
Daggett 3 Solar plus Storage 12/01/2023 123 61.5 63.9
Daggett 2 Solar plus Storage 12/19/2023 65 52 51.5
Estrella Solar plus Storage 12/31/2023 56 28 25.4
Azalea Solar plus Storage 12/31/2024 60 38 40.1
Chalan Solar plus Storage 12/31/2024 65 65 52.6
Arica Solar plus Storage 06/01/2024 93.5 71 64.4
Rexford Solar plus Storage 12/31/2024 300 240 198.2
Desert Quartzite Solar plus Storage 03/01/2025 300 150 111.3 Total 1,110.5 877.5 154.1 140.8 466.6
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42 whether offshore wind is a sensible addition to its portfolio once the cost effectiveness and viability of the resource is better understood.
iv. Out-of-state wind
CPA’s Preferred Conforming Portfolio does not include new wind resources until 2030. Therefore, CPA plans to run competitive solicitations for these resources in the 2026-2028 timeframe. However, should CPA find opportunities to secure these resources prior the 2026—2028, CPA will accelerate procurement of cost-effective, high value wind resources to diversify its portfolio. Currently, the largest barrier for the development of these resources is available transmission capacity to import the resources into CAISO.
v. Other renewable energy not described above
The Preferred Conforming Portfolio anticipates of procurement of new solar resources to come online by 2026. Therefore, CPA plans to run competitive solicitations for these resources in the 2023-2024 timeframe. CPA does not anticipate any material barriers to procuring these resources. vi. Other energy storage not described above
The Preferred Conforming Portfolio anticipates procurement of new storage resources to come online by 2026, either standalone storage or storage paired with solar. Therefore, CPA plans to run competitive solicitations for these resources in the 2023-2024 timeframe. CPA does not anticipate any material barriers to procuring these resources.
vii. Other demand response not described above
CPA has no additional demand response investments other than what is included in the IEPR forecast.
CPA’s demand response program is described further in Section III.b. viii.Other energy efficiency not described above
CPA has no additional energy efficiency investments other than what is included in the IEPR forecast. ix. Other distributed generation not described above
CPA is continuing to procure resources to meet its DAC-GT and CS-GT programs, including negotiations that are currently underway with two community solar projects. CPA is planning to launch its 2022 Power Share RFO in December 2022 to fill its remaining supply needs under the two programs, and will release another RFO in 2023 if additional supply resources are needed to fill CPA’s program cap. CPA’s disadvantaged community programs (aka Power Share) are described further in Section III.b. x. Transportation electrification, including any investments above and beyond what is included in Integrated Energy Policy Report (IEPR) CPA has no additional transportation electrification investments other than what is included in the IEPR forecast. CPA’s transportation electrification program is described further in Section III.b.
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43 xi. Building electrification, including any investments above and beyond what is included in Integrated Energy Policy Report (IEPR)
CPA has no additional building electrification investments other than what is included in the IEPR forecast. CPA’s building electrification program is in development and will be discussed further in the next IRP cycle.
xii. Other
CPA has no other resource types to describe in the Action Plan. b. Disadvantaged Communities
CPA administers several activities and programs that address the needs of disadvantaged communities.
As mentioned above in Section III.d.ii., CPA currently administers Power Share, the Commission-funded DAC/CSGT program. As of October 2022, CPA has fully subscribed eligible customers for the DAC-GT program. CPA manages a waitlist and enrolls eligible waitlisted customers on a monthly basis based on DAC-GT program unenrollment. Once CS-GT projects are live, CPA will enroll customers living in DAC areas within 5 miles of the CS-GT project site. Existing DAC-GT participants that are eligible for CS-GT will first be moved into the CS-GT program and the remaining spots will be filled with new program participants. To ensure that customers in disadvantaged communities are well-informed of Power Share’s benefits, CPA partnered with Active SGV and MERITO Foundation, both organizations promote awareness around climate change, and energy and environment education. Active SGV is a San Gabriel Valley-based community organization in Los Angeles County, and MERITO is based in Oxnard, Ventura County, focused on multi-cultural education and outreach to youth.
Also mentioned in Section III.d.ii., CPA is following through on its Local Programs for Clean Energy Future Strategic Plan to deploy air pollution mitigation programs in Disadvantaged Communities within its territory. After a year of piloting, CPA launched its Power Response Program, a Distributed Energy Resource (DER) based demand response program in January 2022. Participating Power Response customers include residential and commercial customers who are able to reduce their energy usage during peak times. Customers are eligible to participate with behind the meter smart connected energy saving technologies, or by simply manually adjusting their energy usage at their home or business during energy saving events. During these events, customers are asked to reduce their energy usage to relieve strain on the grid when electricity usage is at its highest. Participating customers are eligible to receive enrollment and participation performance incentives, which vary by participation pathway. To broaden the reach of this program in Disadvantaged Communities, CPA’s Power Response program offers a residential behavioral demand response option that does not require smart technology to participate.
CPA is expanding its Power Response program to reach more households, including single and multi-family low-income customers.
In 2021, CPA launched the largest electric vehicle charger installation effort in Ventura County in partnership with the California Energy Commission’s CALeVIP program, the Ventura County Air Pollution District, and Ventura County Regional Energy Alliance. The program offers rebates for the purchase and Agenda Page 68
44 installation of Level 2 and direct current fast chargers. Increased funding was provided for multi-unit dwellings, disadvantaged communities, and low-income communities. CPA plans to launch a similar program in Los Angeles County to again focus a part of the funding on disadvantaged and low-income communities to expand their access to electric vehicle charging infrastructure.
To expand disadvantaged communities’ access to renewable energy, CPA makes available higher tiers of renewable product offerings to all its customers, including its customers that receive rate assistance through the California Alternative Rates for Energy (CARE), Family Electric Rate Assistance (FERA), and Medical Baseline programs. CARE, FERA, or Medical Baseline customers located in jurisdictions that have selected CPA’s 100% renewable as their default energy product are defaulted into CPA’s 100% renewable product at a rate that matches the overall bill cost those customers would pay on SCE’s discounted bundled rate, inclusive of PCIA and their existing discounts. The incremental cost of including customers on discount programs in the 100% renewable default without raising their rates is shared by all other customers, both residential and commercial, in those jurisdictions. This voluntary subsidy provides equitable access to renewable energy options for customers that might otherwise have difficulty accessing other traditional renewable energy programs and avoids automatically increasing generation costs for CPA’s most vulnerable customers. CPA provides this default 100% renewable energy benefit to approximately 38,000 of its 235,000 residential customers that take service on CARE, FERA, and Medical Baseline rate assistance programs. Customers in these three rate assistance programs comprise approximately 27% of CPA’s residential customer accounts.
CPA also has several programs that aim to reach disadvantaged communities and expand their access to the clean energy economy:
• Community Benefits Grant Program: Eligible 501(c)3 organizations can apply and receive between $5,000 to $30,000 for work related to renewable energy research and planning, green workforce development, energy and environmental education, and clean energy in disadvantaged communities. The work has to serve communities within CPA’s service territory.
This program is a partnership between CPA and Calpine Energy Solutions, where Calpine Energy Solutions awards the program funding, and CPA assists in determining the grant guidelines and project criteria and helps recruit organizations to apply for funding. Both entities work together to assess grant applications.
• Voyager Scholarship: This initiative supports students at seven community colleges throughout Los Angeles County and Ventura County and provides financial aid to students enrolled in energy-driven career pathways, such as electric vehicles, energy and environmental science, and alternative energy.
• Workforce development fund: CPA is currently providing funding for a workforce development program partnership with the Los Angeles Cleantech Incubator and supporting students from disadvantaged communities to pursue training focused on microgrid development.
Lastly, as noted in Section II.d, CPA’s estimated local air pollutants are derived from reliance on system power. As CPA continues to increase the portion of its portfolio under long-term contract with clean Agenda Page 69
45 energy resources, as well as bringing online more storage resources to minimize the emissions intensity of system power during net peak load hours, CPA is planning to reduce its reliance on system power. c. Commission Direction of Actions
As an attachment to the Administrative Law Judge’s Ruling Seeking Comments on Staff Paper on Procurement Program and Potential Near-Term Actions to Encourage Additional Procurement (Ruling on Procurement Program), issued on September 8, 2022, CPUC staff proposed two interim approaches to programmatic procurement.
10 Both the resource-specific interim option and the attribute-based interim option would require LSEs to show in 2024 (or another designated year) a portion of forward contracting of some percentage of resources. CPA understands that there is an opportunity to comment on the Staff Paper in December 2022 and will work with CPA’s trade association, CalCCA, to develop comments on this matter. However, given that there is a potential that a portion of the forecasted 2030 resource portfolio may be binding, CPA urges the Commission to clarify its direction on the interim options as soon as possible. If the Commission decides that LSEs have forward contracting obligations in 2024, an expeditious decision would allow LSEs to determine their procurement needs and strategies.
IV. Lessons Learned
In developing the 2022 IRP, CPA notes the different resource cost assumptions it used in its modeling that differ from the assumptions provided by the CPUC, as described in Section II.b. CPA recommends that the CPUC update its resource cost assumptions to reflect significant changes in market conditions and technology costs that have occurred since the last IRP cycle, including rising costs for commodities as well as the passage of the Inflation Reduction Act.
CPA also recommends that the CPUC assess the robustness of its planning tools and consider more sophisticated tools to determine the reliability of LSE portfolios. For example, the CSP tool is a static tool using deterministic sample resource profiles and is not as effective as other tools, such as production cost models, to evaluate reliability of high-renewable penetration portfolios, including curtailment risk. Based on its comparison of estimated emissions from its PLEXOS modeling, CPA believes that the CSP tool is over-estimating the system emissions of the LSE portfolios and potentially leading to overbuild of new resources.
In addition, CPA suggests that the Commission adopt a durable, long-term procurement framework that sets clear carbon-free and renewable procurement goals and allows LSEs to maximize their portfolio planning ability to meet those goals, based on their existing portfolios and other goals set by their local jurisdictions or governing bodies. Based on CPA’s experience in securing resources for the requirements set in D. 21-06-035, the Commission should refrain from requiring the showing of forward contracting more than two years in advance of the online date. While some resources take longer lead time to procure, such as geothermal and out of state wind resources that require import capacity expansion and 10 Pages 41-42, Attachment A of Ruling on Procurement Program.
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46 allocations, the required transmission capacity may not be available at the time of contract execution if LSEs are required to sign contracts in advance to demonstrate compliance. This creates the risk where LSEs would be signing contracts with resources without securing deliverability, and ultimately California ratepayers may not see the RA benefits that they pay for.
Rather than setting forward contracting requirements, the Commission should consider updating the RPS compliance program to include procurement targets for carbon-free resources, in order to achieve the SB 100 carbon-free requirement by 2045. As CPUC staff acknowledges in the Staff Paper, the RPS program has been successful in bringing online renewable resources to meet various statutory requirements. The RPS program’s success is largely due to clear targets set for LSEs, complemented by defined compliance periods where LSEs would need to achieve those targets or face penalties.
The long-term procurement framework should also consider LSE’s best efforts to conduct procurement despite the challenging market conditions that clean energy development is facing, including pandemic related supply chain challenges, rising commodity costs, and significant interconnection delays.
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Staff Report – Agenda Item 4
To: Clean Power Alliance (CPA) Energy Committee
From: John McNamara, Director, Structured Contracts
Approved by: Ted Bardacke, Chief Executive Officer
Subject: 2022 Power Share Request for Offers (RFO)
Date: October 26, 2022
Staff will provide a presentation on the item.
ATTACHMENT
1. 2022 Power Share Request for Offers
Agenda Page 72
2022 Power Share Request for
Offers (RFO)
October 26, 2022
1 ENERGY COMMITTEE - ITEM 4 - ATTACHMENT 1
Agenda Page 73
Executive Summary
2 CPA has an outstanding capacity allocation under its Power Share (DAC-GT and CS-GT) programs
Staff plans to launch the 2022 Power Share RFO in December to solicit offers to fill the outstanding program allocation
CPA must obtain CPUC approval to launch the next Power Share RFO The presentation to Energy Committee today is information only, no action is being requested Program CPA’s Allocation (MW)CPA’s Remaining Allocation (MW) DAC-GT (Existing Power Share) 12.19 3.27
CS-GT (Community Solar) 3.37 3.37
Agenda Page 74
Background
3 In June 2018, the CPUC approved D. 18-06-027 which created the DAC-GT and CS-GT programs CPA was allocated a total of 12.19 MW for its DAC-GT program and 3.37 MW for its CS-GT program • This will provide ~8,600 income-qualified customers in disadvantaged communities with 100% renewable energy from new, DAC-located renewable energy resources
• Currently DAC-GT program is fully enrolled at 6,200 customers • Current Power Share customers are served by interim resources procured from SCE; some of these customers will transition to being served by CPA’s own resources when they come on-line (i.e. recent contracts with ProLogis) The CPUC reimburses CPA for program costs
• CPUC funds above-market procurement costs, the 20% discount on customers’ total electric bill, and CPA’s administration, marketing, education and outreach program implementation costs CPA must implement the programs consistent with CPUC guidelines • Customer and project eligibility
• CPUC approval of CPA program design, RFO solicitations, and PPA • Project energy pricing is subject to a confidential price cap set by the CPUC Agenda Page 75
Power Share – Two Distinct Programs
4 Community Solar
Green Tariff
(CS-GT)
Disadvantaged Community
Green Tariff
(DAC-GT)
Enrolled customers receive 100% renewable energy and a 20% bill discount Promotes the development of renewable generation in and for underserved communities Agenda Page 76
Status of 2021 Power Share RFO
5 The Energy Committee shortlisted 7 projects:
The five Prologis DAC-GT PPAs were approved by the Board in October The two CS-GT projects are currently under negotiation and Staff expects to bring them to the Board for approval in December
Program Project Name Capacity (MW) COD Location
DAC-GT Prologis – Wilmington 1 1.80 12/30/2023 Carson
DAC-GT Prologis - Workman 1.92 12/30/2023 Whittier
DAC-GT Prologis – El Segundo 0.64 12/30/2023 Hawthorne
DAC-GT Prologis – Wilmington 2 0.60 12/30/2023 Carson
DAC-GT Prologis - Dominguez 0.96 12/30/2023 Carson
CS-GT G 0.265 12/1/2023 Pico Rivera
CS-GT H 0.24 12/1/2023 Pico Rivera
Agenda Page 77
Proposed 2022 Power Share RFO
6 CPA has made progress towards filling its program capacity through the 2020 and 2021 Power Share RFOs:
Program CPA’s Allocation
(MW)
2020 Power Share
RFO Procurement
(MW)
2021 Power Share
RFO Procurement
(MW)
CPA’s Remaining
Allocation (MW)
CPA’s Remaining
Allocation (%)
DAC-GT 12.19 3.00 5.92 3.27 27%
CS-GT 3.37 0 0.67* 2.7 80%
*Note the 0.67 MW is capacity from shortlisted CS-GT projects which are currently under negotiation CPA is planning to launch the 2022 Power Share RFO to fill remaining DAC-GT and CS-GT capacity • CPA will need to submit its solicitation materials for CPUC approval, which can take up to 30 days Agenda Page 78
Outreach
7 Prior to the 2021 Power Share RFO, CPA produced a pairing resource to facilitate project partnership, which remains open to interested stakeholders • The pairing resource can be accessed at https://cleanpoweralliance.org/communitysolar/. The resource allows interested parties including site hosts, community sponsors, and project developers to contact each other to evaluate potential Community Solar projects
• CPA will continue to use this pairing resource for the 2022 RFO Over the last couple of months, CPA has been reaching out to member agencies that serve DACs to gauge interest in the upcoming RFO, help them evaluate sites, and encourage them to fill out the pairing resource
CPA is planning to conduct more outreach activities prior to the RFO launch, such as partnering with solar developer groups and outreach to potential developers and community sponsors
Agenda Page 79
Project Eligibility Changes
8 Commercial Online Date – Projects must have an online date no later than 12/31/2025 Project Size – The maximum DAC-GT project size will be reduced from 13 MW to 3.3 MW to target projects that will fill CPA’s remaining program capacity need Changes made in the 2021 Power Share RFO will be carried over, including • Community Solar projects must have a positive determination of Fast Track eligibility • Community Solar projects under 500 kW are eligible to bid but must demonstrate a path towards eligibility to participate in the CAISO market
RFO to be open for six months – Will have two rounds of Q&A opportunities for bidders Agenda Page 80
Proposed RFO Schedule
9 Date Item
December 2022 RFO issuance
January 2023 Bidder webinar with Q&A
February 2023 First round of Q&A responses posted to CPA RFO website March 2023 Deadline for bidders to submit Q&A Questions April 2023 Second round of Q&A responses posted to CPA RFO website June 2023 Deadline for bidders to submittal proposals
August 2023 Bidders notified of shortlist status
August – October 2023 Power Purchase Agreement negotiations and awards September – November 2023 Submit executed PPAs to CPUC for approval* *CPA is required to submit PPAs for CPUC approval within 180 days of bidder’s receipt of shortlist notification Agenda Page 81
Appendix
10 Agenda Page 82
DAC-GT Program Description
DAC-GT customers will receive energy from new Renewable Portfolio Standard (RPS)-eligible projects located within a DAC in Southern California Edison (SCE) territory Project eligibility:
• In-front-of-the meter and 500 kW - 13 MW in size
• New solar, wind, hydroelectric, or biomass/biogas generating facility Eligible customers are CPA customers eligible for the CARE or FERA low-income programs and live within a DAC in CPA territory
• Enrolled customers will receive 100% renewable energy based on their monthly usage at a 20% bill discount
11 Agenda Page 83
Community Solar Program Description
Community Solar customers will receive a portion of the renewable energy output from a local community solar project sized at 3 MW or less
Project eligibility:
• Projects located within a DAC that is within 5 miles of benefitting customers’ DAC census tract • New, RPS-eligible solar, front-of-the-meter generating facility • Community Solar projects require a Community Sponsor1 who assists with customer enrollment and ensures project development is consistent with community priorities Eligible customers must live within a DAC in CPA territory and be within 5 miles of the project location
• Enrolled customers will subscribe to a portion of the Community Solar project capacity based on their historical energy usage
(1) Community sponsors must be a non-profit community-based organization (CBO) or local government entity 12 Agenda Page 84
Community Solar Example – Commercial Site
Example of where the project site is a commercial/industrial building, and the Community Sponsor supports the project:
• Community Sponsor can utilize 25% of the power from the project; the remaining 75% goes to the community’s homes • Community Sponsor is eligible for a 20% bill discount on up to 25% of the project’s output • The Project site generates the power and is compensated through the PPA with the Developer 13 Agenda Page 85
Community Solar Example – Community Site
Example of where the project site is also the Community Sponsor. • Community Sponsor/site can utilize 25% of the power from the project. The remaining 75% goes to the community’s homes
• Community Sponsor/site is eligible for a 20% bill discount on up to 25% of the project’s output • The Project site generates the power and is compensated through the PPA with the Developer 14 Agenda Page 86
Evaluation Criteria
Individual projects received a rank for each of the following criteria, as described in Section 4 of the RFO Protocol:
Environmental
Stewardship
Workforce
Development
Quantitative
Evaluation
Development
Score
Project
Location
Other
Preferences1
In addition, CPA included the following workforce development requirements for all projects:
• Prevailing wage requirements and targeted hire commitments for all projects, with a preference for Project Labor Agreements (PLAs)
(1) Other Preferences – CPA will prioritize projects that leverage other government funding, or that provide evidence of support or endorsements from local climate initiatives 15 Agenda Page 87
DAC-GT and CS-GT CPUC Program Eligibility
Comparison
*Bidders were provided with a mapping tool that allowed them to estimate # of CPA customers within a 5-mile radius
DAC-GT CS-GT
Online Date No later than December 31, 2025 No later than December 31, 2025 Locational Eligibility Projects located within a DAC in SCE territory
Projects located within a DAC that is
within 5 miles of benefitting customers’
DAC census tract*
Project Size 500 kW – 3.3 MW No Minimum; Maximum 3 MW
Generation Type New solar, wind, hydroelectric, or
biomass/biogas RPS-eligible FTM
generating facility
New, RPS-eligible solar, FTM generating
facility
Interconnection Must have completed a Phase I
Interconnection Study or equivalent or
received a positive determination of Fast
Track interconnection eligibility
Must have received a positive
determination of Fast Track
interconnection eligibility
Community Sponsor N/A Projects require a Community Sponsor 16 Agenda Page 88
CPA Territory
DACs in CPA Territory
17 Agenda Page 89
Development Score
Projects will be ranked from high (good) to low (bad)
The development risk metric is a composite rank based on a number of factors impacting project risk:
o Site control
o Interconnection status
o Environmental screens
o Land use and permits
o Project financing
o Developer experience
18 Agenda Page 90
Environmental Stewardship
Projects are ranked high, medium, neutral, and low based on the following prioritization:
Demonstrates multiple benefits (provides additional societal, health, economic, water saving, or environmental benefits beyond the climate and GHG reduction benefits of renewable energy)
HIGH
Located in an area designated as a preferred renewable energy zone and received required land use entitlement permits
MEDIUM
LOW Project is located in a high conflict area
NEUTRAL Project does not demonstrate either preference or avoidance criteria 19 Agenda Page 91
Workforce Development
Projects are ranked high, medium, and low based on the following prioritization:
The project will use targeted-hire, union labor, or multi-trade project labor agreements (including requirements for state-apprenticeship graduates) HIGH The project does not have a labor agreement, but can demonstrate prevailing wage, union labor, and targeted hire commitments MEDIUM The project does not demonstrate prevailing wage, union labor, and targeted hire commitments
LOW
20 Agenda Page 92
Benefits to Disadvantaged Communities
Projects are ranked high, medium, neutral, and low based on the following prioritization:
Located within a DAC and demonstrates DAC workforce and community development benefits HIGH
Project not located within a DAC but can demonstrate DAC benefits and has completed community outreach MEDIUM
LOW Project is inconsistent with community priorities
NEUTRAL Project does not demonstrate DAC benefits
21 Agenda Page 93
Project Location
HIGH In Los Angeles and Ventura counties
MEDIUM Other counties within California
LOW Out of state projects
Projects are ranked high, medium, and low based on the following prioritization:
22 Agenda Page 94