Energy Planning & Resources Committee
of the Clean Power Alliance of Southern California
Regular Meeting
Wednesday, July 26, 2023
12:15 p.m.
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CPA Office
801 S. Grand Ave., Suite 400
Los Angeles, CA 90017
Members of the public may also participate in this meeting remotely at the following locations:
Manhattan Beach City Hall
City Manager Conference Room
1400 Highland Avenue
Manhattan Beach, CA 90266
Alhambra City Hall
Conference Room A
111 S. First St.
Alhambra, CA 91801
Carson City Hall
Executive Conference Room
701 East Carson Street
Carson, CA 90745
Sierra Madre City Hall
Council Chambers
232 W. Sierra Madre Blvd.
Sierra Madre, CA 91024
West Hollywood City Hall
3rd Floor Conference Room
8300 Santa Monica Blvd.
West Hollywood, CA 90069
City of Oxnard Service Center 1
East Conference Room
214 South C Street
Oxnard, CA 93030
Thousand Oaks City Hall
Public Works Conference Room
2100 Thousand Oaks Blvd.
Thousand Oaks, CA 91362
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CALL TO ORDER & ROLL CALL
GENERAL PUBLIC COMMENT
CONSENT AGENDA
1. Approve Minutes from June 28, 2023, Energy Committee Meeting
2. Receive and File June 2023 Risk Management Team Report
REGULAR AGENDA
3. Oral Update from Vice President, Power Supply
4. a. Approve the DAC-GT shortlist as recommended by the 2022 Power Share RFO Review Team
b. Approve the CS-GT shortlist as recommended by the 2022 Power Share RFO Review Team
COMMITTEE MEMBER COMMENTS
ADJOURN – NEXT MEETING AUGUST 23, 2023
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. Public records are available for inspection at CPA’s Office at 801 S. Grand Ave., Suite 400, Los Angeles, CA 90017, or online at www.cleanpoweralliance.org/agendas.
Staff Report – Agenda Item 1
To: Energy Planning & Resources Committee
Subject: Approve the June 28, 2023 Energy Committee Meeting Minutes Date: July 26, 2023
RECOMMENDATION
Approve.
ATTACHMENT
1. Minutes
Energy Planning & Resources Committee Item 1
MINUTES
Energy Planning & Resources Committee
of the Clean Power Alliance of Southern California
Regular Meeting
Wednesday, June 28, 2023, 12:15 p.m.
Meeting videos are available on CPA's YouTube Channel.
http://www.youtube.com/@CPApublicmeetings
Committee Members participated in this meeting from the following locations:
Manhattan Beach City Hall
City Manager Conference Room
1400 Highland Avenue
Manhattan Beach, CA 90266
CPA Office
801 S. Grand Ave., Suite 400
Los Angeles, CA 90017
Alhambra City Hall
Conference Room A
111 S. First Street
Alhambra, CA 91802
Carson City Hall
Executive Conference Room
701 East Carson Street
Carson, CA 90745
West Hollywood City Hall
3rd Floor Conference Room
8300 Santa Monica Blvd.
West Hollywood, CA 90069
Howard Building
368 Queenstown Road
Greater London, SW11
England, United Kingdom
City of Oxnard Service Center 1
East Conference Room
214 South C Street
Oxnard, CA 93030
CALL TO ORDER & ROLL CALL
Chair Parkhurst called the meeting to order at 12:15 p.m. and Gabriela Monzon, Board Clerk, conducted roll call.
ROLL CALL
Alhambra Jeff Maloney Committee Member Remote
Carson Reata Kulcsar Committee Member Remote
Manhattan Beach David Lesser Committee Member Remote
Oxnard Kathleen Mallory Committee Member Remote
Sierra Madre Robert Parkhurst Committee Chair Remote
South Pasadena Diana Mahmud Committee Member Remote
Thousand Oaks Helen Cox Committee Member Absent
West Hollywood Chelsea Byers Committee Member Absent
All votes are unanimous, unless otherwise stated.
Energy Planning & Resources Committee Item 1
GENERAL PUBLIC COMMENT
There was no public comment.
CONSENT AGENDA
1. Approve Minutes from May 24, 2023, Energy Committee Meeting
2. Receive and File May 2023 Risk Management Team Report Motion: Committee Member Mahmud, South Pasadena
Second: Committee Member Lesser, Manhattan Beach
Vote: The consent agenda was approved by a roll call vote with an abstention by Chair Parkhurst on Item 1.
REGULAR AGENDA
3. Oral Update from Vice President, Power Supply
Lindsay Saxby, Vice President, Power Supply, stated that CPA successfully fulfilled its Resource Adequacy (RA) requirements for August and is progressing toward meeting them for September assuming that a new resource comes on-line as anticipated. The California Independent System Operator (CAISO) released their summer 2023 load and resource assessment, which indicates an anticipated moderate surplus due to the addition of new grid capacity and storage projects expected to contribute over 4,000 megawatts of energy. Ted Bardacke, CEO, added that meeting CPA’s 2024 Year-Ahead RA compliance by the end of October remains challenging.
Committee Member Mahmud asked about the Commercial Operation Date (COD) for the referenced contract, and Ms. Saxby stated that it should receive CAISO’s authorization to begin operations next week. In response to Chair Parkhurst’s request for updates regarding the 2024 Year-Ahead RA compliance, staff noted it will continue to procure resources until the deadline and provide updates to the Committee.
4. Review and Recommend Approval of Proposed Energy Risk Management Policy (ERMP) Amendments to the Board of Directors
David McNeil, Chief Financial Officer, presented proposed amendments to the ERMP, which governs the power procurement and related business activities of CPA and undergoes an annual review process. Staff recommends four updates, including adjusting the delegation of transaction execution authority, revising hedge target ranges, refining compliance measurement timing language, and adjusting language to reflect regulatory and market changes. The proposed updates to delegation of authority include adding maturity limits and term limits, reducing the term limit for tolling agreements from 5 years to 3 years, increasing the term limit for existing resources from 5 years to 10 years, and eliminating sole CEO approval authority. Staff proposes adopting quarterly hedge targets, increasing the upper and lower renewable energy hedge targets, increasing the upper carbon-free hedge targets, including the current year in renewable and carbon-free hedge targets, and increasing the minimum targets for RA. Lastly, staff recommends revising the measurement timing for energy, renewable energy, carbon-free energy, and RA to clarify implementation.
Committee Member Lesser requested further context on the origins of the policy and any metrics or regulatory considerations used to construct the policy and
Energy Planning & Resources Committee Item 1
amendments. Mr. McNeil explained that the ERMP is an industry best practice used to manage procurement activities and is governed by the Board, requiring an annual review and updates to manage risks effectively. Matt Langer, Chief Operating Officer, added that proposed amendments stem from challenges that arise during the regular course of business. Committee Member Mahmud asked about the impact of regulatory requirements. Mr. Langer indicated that in response to the changing regulatory environment, staff may incorporate aspects of new regulatory requirements into the ERMP as needed. Committee Member Kulcsar asked clarifying questions about RMT delegations and the CEO signing authority, distinctions between short- and long-term contracts, and dollar limits set by the Board for energy risk hedging strategy. Staff clarified that the RMT approves contracts governed by credit and notional limits, not a dollar amount. Staff proposes that for different transaction types, the definition of short- and long-term would change; long-term tolling agreements would be defined anything more than three years and whereas long term contracts for new construction other than tolling agreements would remain at anything more than five years, as is currently the case. The delegation of authority depends on the transaction type and associated risks. Regarding energy risk hedging limits, Mr. Langer explained that there is no dollar value limit associated with the hedging strategy, as it would hinder staff from executing transactions swiftly and expose customers to volatile market prices. The proposed amendments to the ERMP aim to increase the hedging target ranges to provide staff with greater flexibility. Any deviations from the ERMP are reported monthly to the Energy and Finance Committees, while the activities of the RMT are reported to the Board on a quarterly basis.
Committee Member Mahmud suggested including the member composition of the RMT in the ERMP, and staff agreed to incorporate the suggestion. Committee Member Kulcsar expressed discomfort with contract term limits beyond five years that did not go to the Board. Committee Member Lesser voiced support for the recommended amendments and noted that more context would help with decision-making at the Board level. Committee Member Mallory asked about the economic impacts of increasing term limits beyond five years. Staff explained that contract deliveries become financial commitments in the year they occur, which can be at any point within the contracted timeframe. The recommended amendments aim to reduce future procurement costs, which in turn can help keep rates competitive.
Committee Member Maloney explained that the ERMP provides staff with Board-approved guidelines in order to operate in the energy market, and the organization has greatly benefitted from it; he expressed support for the amendments as they circumscribe delegation of authority to staff even further while providing the necessary flexibility. Committee Member Mahmud added that limiting the expansion of the delegation of authority to existing facilities poses less risk, and staff will continue to utilize most of the delegation of authority with short-term contract extensions.
Motion: Committee Member Mahmud, South Pasadena
Second: Committee Member Maloney, Alhambra
Vote: Item 4, with one additional amendment to include the RMT member composition, was approved by a roll call vote, with a no vote from Committee Member Kulcsar.
Energy Planning & Resources Committee Item 1
COMMITTEE MEMBER COMMENTS
Committee Member Lesser thanked Chair Parkhurst for his inclusive chairmanship of the Committee.
ADJOURN
Chair Parkhurst adjourned the meeting at 1:29 p.m.
Staff Report – Agenda Item 2
To: Energy Planning & Resources Committee
From: Geoff Ihle, Director, Energy Market Risk Manager
Approved By: Ted Bardacke, Chief Executive Officer
Subject: Risk Management Team Report
Date: July 26, 2023
June 2023 RMT REPORT
Key Actions
• Reviewed current counterparty credit exposure
• Reviewed May 2023 market performance
• Reviewed May 2023 generation and storage performance
• Reviewed energy positions and approved 2023-2027 hedges • Reviewed March 2023 day-ahead load forecast performance • Reviewed positions for RPS and carbon free products
• Reviewed Resource Adequacy (RA) positions, including CPA’s 2023 and 2024 Month-Ahead and 2024-2027 Year-Ahead open position and procurement strategy • Reviewed Energy Risk Management Policy (ERMP) compliance • Reviewed June 2023 CRR Allocations and Auction results and 2023 YTD performance
Energy Planning & Resources Committee Item 2
Policy Compliance
Policy Deviation Required Action
Carbon Free Energy: As of December 1,
2022, carbon free energy under contract
for 2023 was above the ERMP maximum
of 100%.
None. At its May 4, 2023, meeting the
Board approved new 2023 Lean Power
product contents which increased CPA's
2023 carbon free target and cured the
December 1, 2022, policy deviation.
Resource Adequacy: As of December 1,
2022, July, August and September 2023
Resource Adequacy under contract was
below the ERMP hedge minimum of 90%
of the Month-Ahead compliance
requirement.
None. As a result of procurement
activity, CPA cured the July, August and
September 2023 policy deviations. CPA
met its July, August and September
2023 Month-Ahead CPUC RA
compliance requirements ahead of the
monthly filing deadlines.
Staff Report – Agenda Item 3
To: Energy Planning & Resources Committee
From: Lindsay Saxby, Vice President, Power Supply
Subject: Oral Update from Vice President, Power Supply
Date: July 26, 2023
The VP will provide an oral report on CPA energy procurement activities, including:
• September Resource Adequacy compliance update
• Clean Energy and Reliability RFO update
• Heatwave and grid resiliency
Staff Report – Agenda Item 4
To: Energy Planning & Resources Committee
From: Lindsay Saxby, Vice President, Power Supply
Approved By: Ted Bardacke, Chief Executive Officer
Matthew Langer, Chief Operating Officer
Subject: 2022 Power Share Request for Offers (RFO)
Date: July 26, 2023
RECOMMENDATION
a. Approve the DAC-GT shortlist as recommended by the 2022 Power Share RFO Review Team
b. Approve the CSGT shortlist as recommended by the 2022 Power Share RFO Review Team
ATTACHMENT
1. 2022 Power Share RFO Shortlist Recommendation
2022 Power Share Request for
Offers (RFO) Shortlist
July 26, 2023
Executive Summary
2 Under two CPUC-approved programs (DAC-GT and CSGT1), CPA may procure energy from small-scale renewable projects within Disadvantaged Communities (DACs)2 in order to provide 100% renewable energy to low-income customers at a 20% bill discount CPA markets these programs under the “Power Share” brand In December 2022, CPA launched the 2022 Power Share RFO, with bids due on June 1, 2023; this RFO is the third RFO supporting CPA’s Power Share program3 An RFO Review Team including Energy Committee members reviewed confidential offer information and developed two recommended shortlists, one for DAC-GT and one for CSGT Each recommended shortlist will fill CPA’s DAC-GT and CSGT program capacity caps ACTION REQUESTED: Approve (a) the DAC-GT shortlist and (b) the CSGT shortlist as recommended by the RFO Review Team
(1) Disadvantaged Community Green Tariff (DAC-GT) and Community Solar Green Tariff (CSGT) (2) DACs are defined as communities that are identified in the CalEnviroScreen 3.0 as among the top 25 percent of census tracts statewide, plus the census tracts in the highest five percent of CalEnviroScreen’s Pollution Burden that do not have an overall CalEnviroScreen score because of unreliable socioeconomic or health data. (3) Previous RFOs were released in 2020 and 2021
Agenda
3 Background
Disadvantaged Community Green Tariff Offers
Community Solar Green Tariff Offers
Recommendations
Background
4
Disadvantaged Communities (DAC) Programs
5 Community Solar
Green Tariff
(CSGT)
Disadvantaged Community
Green Tariff
(DAC-GT)
CPA Branded as “Power Share”
Enrolled customers receive 100% renewable energy and a 20% bill discount Promotes the development of renewable generation in and for underserved communities
Regulatory Background
6 In June 2018, the CPUC approved D. 18-06-027 which created the DAC-GT and CSGT programs
CPA was allocated a total of 12.19 MW for its DAC-GT program and 3.37 MW for its CSGT program
o This provides ~7,600 income-qualified customers in disadvantaged communities with 100% renewable energy from new, DAC-located renewable energy resources The CPUC makes CPA whole on program costs
o CPUC funds the above-market procurement cost for these resources, the 20% discount on customers’ total electric bill, and CPA’s program implementation costs (administration, marketing, education and outreach)
CPA must implement the programs consistent with CPUC guidelines o Customer and project eligibility
o CPUC-approved program design and RFO solicitations, including PPA approval
Green Access Program (GAPs) Review
7 • The CPUC is currently evaluating whether the DAC-GT and CSGT programs should be modified, terminated, or expanded in its GAPs proceeding • CCAs submitted recommendations to improve DAC-GT and CSGT by easing siting requirements and including storage as an option for future project offerings • The GAP review could end the DAC-GT and CSGT programs for future solicitations.
Therefore, it is highly advisable to fill the entire program allocation now to able to continue to serve the maximum amount of customers
Current RFO and DAC Program Position
8 Through the 2020 and 2021 Power Share RFOs, CPA made significant progress filling its DAC-GT and CSGT program allocations, with 6 DAC-GT and 2 CSGT projects under contract The 2022 Power Share RFO was released in December 2022, with offers due on June 1, 2023 9 project offers were received in the 2022 RFO:
o DAC-GT – 6 rooftop offers and 1 ground-mount offer
o CSGT – 2 rooftop offers
These 2022 Power Share RFO offers could fill CPA’s total program allocation CPA’s Total Allocation
(MW)
2020 DAC RFO Procured
Capacity (MW)
2021 DAC RFO Procured
Capacity (MW)
CPA’s Remaining
Allocation
(MW)
DAC-GT 12.19 3.00 5.92 3.27
CSGT 3.37 0.00 0.67 2.7
DAC-GT
Disadvantaged
Community Green
Tariff Offers
9
DAC-GT Program Description
DAC-GT customers receive energy from new Renewable Portfolio Standard (RPS)-eligible projects located within a disadvantaged community (DAC) in Southern California Edison (SCE) territory
Enrolled customers must be eligible for the CARE or FERA low-income programs and live within a DAC in CPA territory
o Enrolled customers will receive 100% renewable energy based on their monthly usage at a 20% bill discount
o ~6,000 current Power Share (DAC-GT) customers are being served by interim resources acquired from Southern California Edison
CPA has contracted with 6 DAC-GT projects to-date, 5.92 MW of DAC-GT capacity is expected to come online by April 2024, another 3 MW of capacity is expected online in December 2024
Current DAC-GT customers will be transitioned to the new resources as they come online 10
DAC-GT Offers Results Summary
CPA received 1 offer for ground-mounted solar PV from Developer A o While the highest ranked quantitatively, the Review Team did not recommend shortlisting this offer due to a low environmental stewardship score and CPA’s preference for local projects
CPA received 6 offers from Developer B for rooftop solar projects totaling 4.84 MW of capacity located in Carson and Commerce o The Review Team recommends shortlisting the top 4 highest ranked offers; the cumulative capacity of these 4 projects is 3.44 MW and will fill CPA’s remaining DAC-GT program allocation of 3.27 MW with an excess of 0.17 MW
o The developer of Project E is exploring reducing the size of Project E by 0.17 MW. This would ensure that CPA’s program capacity allocation is filled exactly, ensuring that CPA can recover all associated above-market costs
If project-downsizing is not feasible, the Review Team recommended that CPA move forward with the maximum project sizes o Doing so would result in a nominal cost to CPA over the life of the contracts 11 Review Team
Recommendation Developer Project Capacity (MW) Technology Term
(years)
Commercial
Online Date Location
Environmental
Stewardship
Benefits
to DACS
Workforce
Development
Project
Location
Development
Score
Average
Generation
(MWh/year)
Don't Shortlist A A 3.00 Solar PV – Ground-mount 15 12/31/2025 Cantil - Kern
County Low High High Medium High 10,079.60
Shortlist B B 1.24 Solar PV – Rooftop 20 6/1/2025 Commerce High High High High High 2,762.00 Shortlist B C 0.68 Solar PV – Rooftop 20 6/1/2025 Carson High High High High High 1,504.93 Shortlist B D 0.68 Solar PV – Rooftop 20 6/1/2025 Commerce High High High High High 1,507.00 Shortlist B E 0.67- 0.84 Solar PV – Rooftop 20 6/1/2025 Commerce High High High High High 1,845.00 Don't Shortlist B F 0.56 Solar PV – Rooftop 20 6/1/2025 Carson High High High High High 1,210.79 Don't Shortlist B G 0.84 Solar PV – Rooftop 20 6/1/2025 Commerce High High High High High 1,838.00
DAC-GT Shortlist Recommendation
The Review Team recommends shortlisting the below projects, all from Developer B 12 Program Project Capacity (MW)
Commercial Online
Date Location
DAC-GT B 1.24 6/1/2025 Commerce
DAC-GT C 0.68 6/1/2025 Carson
DAC-GT D 0.68 6/1/2025 Commerce
DAC-GT E 0.67 - 0.841 6/1/2025 Commerce
PPA execution with all projects recommended for the shortlist would fill CPA’s program allocation for DAC-GT:
CPA’s Total Allocation CPA’s Remaining
Allocation
2022 DAC RFO Shortlist
Recommendation
CPA’s Remaining
Allocation after
Recommendation
DAC-GT 12.19 MW 3.27 MW 3.44 MW 0 MW - Long 0.17 MW
(1) CPA is seeking to reduce the size of Project E by 0.17 MW. This would ensure that CPA’s program capacity allocation is filled exactly, and CPA can recover all associated above-market costs
CSGT
Community Solar
Green Tariff
13
CSGT Program Description
14 CSGT customers will receive a portion of the renewable energy output from a local community solar project
Projects must be located within a DAC that is within 5 miles of CPA customers’ DAC census tract
CSGT projects require a Community Sponsor1 who assists with customer enrollment and ensures project development is consistent with community priorities o The Community Sponsor may receive 25% of the project's output and receive a 20% bill discount on that energy
CPA has contracted with one developer for two CSGT projects to-date. A total of 0.67 MW of capacity is expected to come online by the end of 2023, serving approximately 340 customers in the Bassett-Avocado Heights neighborhood of unincorporated LA County
o The Bassett Unified School District is the Community Sponsor (1) Community sponsors must be a non-profit community-based organization (CBO) or local government entity
CSGT Offer Results Summary
15 CPA received 2 offers from Developer B for rooftop solar projects located in Carson o The Review Team recommends shortlisting both offers; the cumulative capacity of the projects is 2.76 MW and will fill CPA’s remaining CSGT program allocation of 2.7 MW with an excess of 0.06 MW
o CPA is exploring reducing the size of Project I by 0.06 MW with Developer B. This would ensure that CPA’s program capacity allocation is filled exactly, and CPA can recover all associated above-market costs
If project-downsizing is not feasible, CPA will move forward with the maximum project sizes recommended by the Review Team o Doing so would result in a nominal cost to CPA over the life of the contracts The City of Carson is the Community Sponsor for both projects and would receive 25% of the project output and a 20% bill discount for the associated energy The projects can serve CPA customers in Carson, Paramount, and unincorporated Los Angeles County. Over 31,000 eligible CPA customers reside within a 5- mile radius of the projects
Recommendation Project Capacity
Term
(years)
Commercial
Online Date Location
Environmental
Stewardship
Benefits
to DACS
Workforce
Development
Project
Location
Developm
ent Score
Average
Generation
(MWh/year)
Shortlist H 1.32 20 6/1/2025 Carson High High High High High 2,919.50 Shortlist I 1.38 - 1.44 20 6/1/2025 Carson High High High High High 3,239.79
Recommended CSGT Projects
A number of CPA DAC
communities, shown in dark red,
are located within a 5-mile radius
from the CSGT projects
If a portion of a DAC census tract
is within 5 miles of the project
site, the entire census tract is
eligible
Over 31,000 eligible CPA
customers reside within this
territory
16
CSGT Shortlist Recommendation
The Review Team recommends shortlisting the below projects, all from Developer B 17 Program Project Capacity (MW)
Commercial
Online Date Location
CSGT H 1.32 6/1/2025 Carson
CSGT I 1.38 - 1.441 6/1/2025 Carson
PPA execution with all projects recommended for the shortlist would fill CPA’s program allocation for CSGT and DAC-GT:
CPA’s Total Allocation CPA’s Remaining
Allocation
2022 DAC RFO
Shortlist
Recommendation
CPA’s Remaining
Allocation after
Recommendation
CSGT 3.37 MW 2.7 MW 0.505 MW 0 MW - Long 0.06 MW
(1) CPA is seeking to reduce the size of Project I by 0.06 MW. This would ensure that CPA’s program capacity allocation is filled exactly, and CPA can recover all associated above-market costs
Next Steps
18
Next Steps
19 Date Action
July 26, 2023 Energy Committee shortlist consideration
August 1, 2023 Bidders notified of shortlist status
August 2023 – September 2023 PPA negotiations
September 2023 – January 2023 Board consideration of PPAs January 30, 2023 Executed PPAs submitted to CPUC for approval* *CPA is required to submit executed PPAs for CPUC approval within 180 day of bidders’ receipt of shortlist notification
Actions Requested
20 a) Approve the DAC-GT shortlist as recommended by
the 2022 Power Share RFO Review Team
b) Approve the CSGT shortlist as recommended by the
2022 Power Share RFO Review Team
Appendix
DAC-GT and CSGT Eligibility Comparison
DAC-GT CSGT
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 – 3.27 MW No Minimum; Maximum 2.7 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 eligibility
The project must have received a positive
determination of Fast Track eligibility
Community Sponsor N/A Projects require a Community Sponsor 22
RFO Evaluation Criteria
Individual projects received a rank for each of the following criteria:
In addition, CPA included the following workforce development requirements for all projects:
o Prevailing wage requirements and targeted hire commitments for all projects, with a preference for Project Labor Agreements (PLAs)
Environmental
Stewardship
Workforce
Development
Quantitative
Evaluation
Development
Score
Project
Location
Other
Preferences1
23 (1) Other Preferences – CPA will prioritize projects that leverage other government funding, or that provide evidence of support or endorsements from local climate initiatives.
Valuation Results
All 2022 Power Share RFO offers were priced under the CPUC-designated price cap o The CPUC funds any above-market costs that CPA incurs for the procured power In addition, the RFO Review Team evaluated the offer prices against historical offer prices for relevant solicitations, and deemed them reasonable
o Offers in the RFO were compared to rooftop and small-scale ground-mounted solar from the 2021 and 2020 Power Share RFOs and the 2019 Distributed Track RFO o Utility-scale solar offer prices are lower, but are not a good benchmark for Power Share RFO offer prices
24