Template posted by Commission on January 16th, 2026
Standard LSE Plan
REDWOOD COAST ENERGY AUTHORITY
2025 INTEGRATED RESOURCE PLAN
AUGUST 10, 2026
1 Table of Contents
I. Executive Summary.................................................................................................. 3 II. Study Design ........................................................................................................... 11 a. Objectives............................................................................................................. 11 b. Methodology ....................................................................................................... 11 i. Modeling Tool(s)............................................................................................. 11 ii. Modeling Approach ....................................................................................... 13 iii. Alternative Assumptions ......................................................................... 17 III. Study Results....................................................................................................... 18 a. Conforming and Alternative Portfolios .......................................................... 18 b. Preferred Conforming Portfolio ....................................................................... 23 c. GHG Emissions Results ..................................................................................... 29 d. Local Air Pollutant Minimization and Disadvantaged Communities ....... 30 i. Local Air Pollutants........................................................................................ 30 ii. Focus on Disadvantaged Communities ...................................................... 31 e. Cost and Rate Analysis ...................................................................................... 33 f. System Reliability Analysis............................................................................... 35 g. Existing Resource Planning............................................................................... 36 h. Hydro Generation Risk Management ............................................................. 38 i. Long-Duration Storage Planning ..................................................................... 39 j. Clean Firm Power Planning.............................................................................. 40 k. Non-CAISO, including Out-of-State, Wind Planning................................... 45 l. Offshore Wind Planning.................................................................................... 45 m. Transmission Planning .................................................................................. 47 IV. Action Plan .......................................................................................................... 50 a. Proposed Procurement Activities and Potential Barriers............................. 50 i. Resources to meet IRP mandated procurement requirements, including D.21- 06-035 and D.23-02-040:........................................................................................... 50 2 ii. Plans for resources that are currently non-candidate in CPUC’s IRPs not described above......................................................................................................... 53 iii. Offshore wind ............................................................................................. 54 iv. Out-of-state wind........................................................................................ 54 v. Other renewable and/or zero carbon resources not described above .... 54 vi. Other energy storage not described above ............................................. 57 vii. Other demand response not described above........................................ 57 viii. Other energy efficiency not described above ......................................... 58 ix. Other distributed generation not described above.................................... 59 x. Transportation electrification, including any investments that correspond to different levels than what is included in Integrated Energy Policy Report (IEPR)............................................................................................... 60 xi. Building electrification, including any investments that correspond to different levels than what is included in Integrated Energy Policy Report (IEPR)........................................................................................................................ 62 xii. Potential Centralized Procurement, pursuant to AB-1373 ............................ 63 xiii. Other............................................................................................................. 63 b. Disadvantaged Communities (DACs)............................................................. 66 c. LSEs’ Tribal Customers...................................................................................... 68 d. Procurement Products ....................................................................................... 69 e. Commission Direction of Actions .................................................................... 70 V. Lessons Learned...................................................................................................... 71 3 I. Executive Summary
Introduction to RCEA
Formed in 2003, Redwood Coast Energy Authority (“RCEA”) is a joint powers authority governed by the County of Humboldt, the Cities of Arcata, Blue Lake, Eureka, Ferndale, Fortuna, Rio Dell, and Trinidad, the Yurok Tribe, and Blue Lake Rancheria. RCEA is controlled by and accountable to these member agencies and their respective constituents. RCEA’s mission is to develop and implement sustainable energy initiatives that reduce energy demand, increase energy efficiency, and advance the use of clean, efficient and renewable resources available in the region.
RCEA became a Community Choice Aggregator (“CCA”) in October 2016 with the submission of its Implementation Plan to the California Public Utilities Commission (“CPUC” or “Commission”) and began serving load in May 2017. Through its CCA, RCEA provides electric generation services and customer energy programs to ratepayers within Humboldt County. RCEA’s service area is identified in Figure 1.
4 Figure 1: RCEA Service Area Map
RCEA has had a stable participation rate of about 92% since the initial launch phase of the CCA, which is equivalent to about 62,000 electric accounts. Residential customers make up about 90% of the accounts and about 50% of electricity sales, with the remainder being commercial and industrial customers. RCEA serves an annual load of about 530 GWh with an average annual peak demand of about 100 MW.
● The following are relevant objectives from RCEA’s Board-adopted RePower Humboldt Comprehensive Action Plan for Energy (“Strategic Plan”) that are instrumental RCEA’s IRP development process.Minimize GHG Emissions Associated with RCEA’s CCA Program. Procure 100% carbon-free and renewable energy on an annual basis starting in2025.
5 ● Maximize Renewable Energy Content of RCEA’s CCA Program. Procure 100% renewable energy on an annual basis by 2030.
● Maximize Local Energy Content of RCEA’s CCA Program. To the extent technically feasible and economically prudent, support development of resources located within or near the Humboldt Local Reliability Area through procurement. ● Provide CCA Program Customer Rate Savings. Provide customer rates that are affordable and price-competitive with customers’ other electric supply options.
Consistent with Public Utilities Code (“PUC”) Sections 366.2(a)(5) and 454.52 (b)(3), RCEA procurement staff strive to ensure all procurement by RCEA, including the portfolios set forth in this IRP, is aligned with these board-adopted goals.
Summary of RCEA’s IRP
In accordance with the requirements of California PUC Sections 454.51 and 454.52, Commission Decisions (“D.”) 18-02-018, D.19-11-016, D.20-03-028, and D. 22-02-004 (and subsequent updates to D. 22-02-0041), RCEA is providing its Integrated Resource Plan (“IRP”) to the Commission for review, certification and use in the Commission’s statewide planning processes.
In addition to this narrative, RCEA’s IRP includes the following documents:
• RCEA’s Resource Data Template (“RDT”)
• RCEA’s 8 million metric ton (“MMT”) Clean System Power calculator tool (“CSP calculator”)
The planned resources identified in RCEA’s IRP represent RCEA’s good-faith projection of the resource mix that it will procure over the IRP planning horizon, based on the best information currently available. The planned portfolio identified in future iterations of RCEA’s IRP may change and the actual resource mix RCEA procures may differ, due to changes in regulatory 1 The 2021 PSP Portfolio was updated by IRP staff with more recent Inputs and posted on the IRP website on June 15, 2022. In all instances where this narrative references D. 22-02-004, it is also referring to the updated guidance.
Updated guidance is located here: https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/integrated-resource-plan-and-long-term-procurement-plan-irp-ltpp/2022-irp-cycle-events-and-materials/lse-filing-requirement-resolve-results.pdf 6 policy and market trends that affect availability and price of supply, as well as changes in load relative to forecast.
As directed in the January 16, 2026 Administrative Judge’s Ruling Setting Requirements for Individual Integrated Resource Plans (“IRP Requirements Ruling”), RCEA is submitting one conforming portfolio that has lower GHG emissions than RCEA’s proportional share of the 8 MMT GHG emissions benchmark for the electric sector in 2045. RCEA’s governing board has approved this portfolio, indicating its consistency with RCEA’s strategic goals. This portfolio reflects actual planned procurement and is consistent with the action plan described in Section IV.
This narrative provides a detailed description of the development and content of RCEA’s 2045 8 MMT Preferred Conforming Portfolio, its compliance with applicable requirements, and an action plan detailing RCEA’s planned next steps. RCEA developed its IRP through the following steps:
1. Compiled contracted and owned generation and storage resources, both operational and in-development.
2. Compiled anticipated resource procurements currently under review and to which RCEA has exclusive procurement rights.
3. Identified generic candidate resources that are compatible with RCEA’s Strategic Plan and the CPUC’s new resource portfolio transmitted to CAISO for the 2025-2026 Transmission Planning Process (“TPP Portfolio”), and constrained their capacities according to current procurement and development expectations.
4. Identified policy resources, such as offshore wind and enhanced geothermal capacity, to include in the portfolio.
7 5. Selected resource pricing assumptions from the CPUC’s 2024-2026 IRP Inputs & Assumptions Report 2, as well as RCEA’s experience in the bilateral market.
6. Conducted portfolio optimization modeling to select generic candidate resources to fill RCEA’s open position relative to its assigned load forecast.
7. Presented two portfolio options to the RCEA Board of Directors for feedback: one which included the policy resources as contracted, and another which filled the open position solely based on economic performance; took direction from the Board to proceed using the policy-based portfolio.
8. Reran the portfolio optimization model incorporating feedback from the Board.
9. Populated the RDT and CSP calculator with the final portfolio of supply resources, assigned forecasts for managed retail sales, peak demand, and BTM PV and RCEA’s custom load profile.
10. Compiled RCEA’s long-term resource adequacy (“RA”) contracts which were not included in the portfolio optimization modeling since they do not contribute energy.
Identified the effective capacity shortfall in the RDT and added short-term RA contracts until the reliability need was satisfied.
11. Identified the resulting portfolio as its Preferred Conforming Portfolio and obtained authorization from the RCEA Board of Directors to submit to the CPUC.
In addition to RCEA’s contracted operational and in-development resources, the Preferred Conforming Portfolio includes the following planned resources that have not yet been contracted:
• 10 MW Small Hydropower
• 10 MW North Coast Offshore Wind
• 9.5 MW Central Coast Offshore Wind
2 https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/integrated-resource-plan-and-long-term-procurement-plan-irp-ltpp/2024-2026-irp-cycle-events-and-materials/2025_inputs_and_assumptions_report_20260210.pdf 8 • 16.5 MW In-State Enhanced Geothermal Projects
• 26 MW Generic In-State Enhanced Geothermal
• 120 MW Generic Out-of-State Geothermal
• 200 MW Generic Large-Scale Solar
• 72 MW Generic In-State Onshore Wind
• 75 MW Generic Battery Storage
The portfolio provides for the following overall resource mix in 2045:
• 215 MW Solar
• 76 MW Onshore Wind
• 19.5 MW Offshore Wind
• 167 MW Geothermal
• 18 MW Biomass
• 10 MW Small Hydro
• 230 MW / 920 MWh Short-Duration Storage
• 3 MW / 24 MWh Long-Duration Storage
RCEA reached the following findings regarding its Preferred Conforming Portfolio:
• The planned new resources are consistent with procurement timing, resource quantities, and technology types identified in the 2025-2026 TPP Portfolio. • The portfolio would have 2045 GHG emissions of -0.153 MMT according to the CSP calculator, which is lower than RCEA’s assigned 2045 GHG emissions benchmark of
0.022 MMT. All interim planning years are also below the interim GHG emissions benchmarks.
• The portfolio meets the Commission’s perfect capacity equivalent standard. • The portfolio provides more than RCEA’s load-proportional share of renewable integration resources.
RCEA’s Preferred Conforming Portfolio is consistent with its program goals and Board directives, while contributing its share of renewables integration and reliability at a forecasted 9 cost that is affordable to RCEA customers. To implement its Preferred Conforming Portfolio, RCEA is adopting the action plan described in Section IV and summarized below. • Continue to procure remaining Mid-Term Reliability (“MTR”) capacity obligation, specifically long-lead time resources mandated by D. 26-02-057, and monitor development progress of procured capacity;
• Secure import allocation rights for out-of-state long-lead time MTR resources; • Continue to engage on offshore wind development on the Central and North Coasts in spite of opposition by the federal administration;
• Continue to procure local biomass power and investigate opportunities for alternative uses of biomass waste;
• Continue supporting development of geothermal power, especially enhanced geothermal technologies in California, specifically through CC Power’s Strategic Geothermal Initiative;
• Pursue development of local small hydropower;
• Continue administering energy efficiency and building electrification programs, through CCA funding and through the Northern Rural Regional Energy Network; • Continue incentivizing transportation electrification through planning, grants and rebate programs;
• Reduce reliance on large hydropower, unspecified power, and natural gas RA capacity; and
• Ensure best outcomes for disadvantaged communities.
Board Approval of IRP
In compliance with PUC Section 454.52(b)(3), on July 23, 2026, this IRP was formally submitted to RCEA’s Board of Directors for approval based on the IRP’s compliance with PUC Sections 454.51 and 454.52 (“IRP Statute”) and all relevant procurement requirements adopted by RCEA’s governing board.
Request for Certification
10 RCEA respectfully requests that the Commission certify this IRP. As both the Legislature and the Commission have recognized, the Legislature has granted CCAs broad authority to procure resources on their customers’ behalf, an authority limited only where “other generation procurement arrangements have been expressly authorized by statute.” 3 Likewise, the Legislature has granted CCAs autonomy in setting their own rates and managing interactions with their customers. 4 The Commission has three primary interests in the CCA IRP process:
• Ensuring that CCA IRPs provide the CCA procurement information that the Commission needs to develop its statewide plan. 5
• Ensuring that CCAs’ current and planned procurement is consistent with the RA requirements established pursuant to PUC Section 380. 6 • Ensuring that each CCA’s current and planned procurement satisfies the CCA’s share of renewables integration resources identified in the Commission’s 2025-2026 TPP Preferred System Portfolio, and that the CCA either self-provides or pays for IOU procurement for its share of any renewable integration shortfall. 7 RCEA has prepared its IRP with these interests in mind, and thanks the Commission in advance for its recognition of CCA procurement autonomy and the benefits of a collaborative approach with CCAs in its certification review of RCEA’s IRP.
3 PUC Section 366.2(a)(5).
4 D.05-12-041 at 5 (“Nothing in the statute directs the CPUC to regulate the CCA’s program except to the extent that its programs may affect utility operations and the rates and services to other customers. For example, the statute does not require the CPUC to set CCA rates or regulate the quality of its services”); D.19-04-040 at 18 (“the Commission does not approve CCA or ESP rates”).
5 D.19-04-040 at 17-18 (“The Commission’s portfolio aggregation and evaluation process, which relies on fulfillment of IRP filing requirements by LSEs, is the only process capable of assessing the overall needs of the CAISO grid and meeting the statewide GHG, reliability, and least-cost goals collectively. While LSEs may use their IRP process to meet local planning needs as well, the statewide planning function is the statutorily required process…”). 6 PUC Section 454.52(b)(3)(C).
7 PUC Section 454.51.
11 II. Study Design
a. Objectives
In conducting the analytical work documented in this IRP, RCEA aimed to develop a portfolio that met the following objectives:
1. Achieve GHG emissions equal to or less than RCEA’s proportional share of the 8MMT GHG target by 2045, as determined using the Commission’s CSP calculator.
2. Achieve economic, reliability, environmental, security, and other benefits and performance characteristics that are consistent with the goals set forth in PUC Section 454.52(a)(1)(A-I).
3. Identify a diverse mix of power resources that relies mostly on in-state, new build projects.
4. Achieve the RA requirements established pursuant to PUC Section 380 and provides RCEA’s share of system reliability and renewable integration resources.
5. Align with RCEA’s Strategic Plan and other Board-adopted procurement directives.
6. Comply with RCEA’s procurement obligations under the Renewables Portfolio Standard and IRP Procurement Orders.
7. Support transmission planning for large-scale, in-state new resources, such as offshore wind and geothermal.
8. Identify a portfolio that is cost-effective and minimizes rate impacts on RCEA’s customers.
b. Methodology
i. Modeling Tool(s)
RCEA used multiple modeling tools to develop its IRP, including Python for Power System Analysis (“PyPSA Model”), an open source portfolio optimization model, and the CSP calculator developed by the CPUC. RCEA used the PyPSA Model to build portfolio evaluation scenarios.
RCEA used these results to evaluate the incremental value of each candidate resource and 12 portfolio configuration. Finally, RCEA evaluated the overall financial impact of its Preferred Conforming Portfolio on RCEA’s financial outlook utilizing PyPSA outputs that track portfolio optimization outcomes in a least-cost framework.
PyPSA Optimization Model
PyPSA (Python for Power System Analysis) is an open-source framework for simulating and optimizing modern power systems. The multi-period investment optimization feature simultaneously optimizes capacity expansion across all investment periods (2026–2045), enabling the model to weigh near-term costs against long-term benefits while respecting technology learning curves, policy constraints (including the 8 MMT GHG emissions by 2045 mandate), and resource availability windows. By co-optimizing dispatch and investment decisions across the full planning horizon at once, PyPSA identifies least-cost portfolio pathways that meet both reliability and decarbonization objectives.
The model represents RCEA’s system as a two-node network — an RCEA node, comprising RCEA’s existing and contracted resource stack, and a Market (MKT) node, comprising candidate resources RCEA is evaluating for procurement — connected by a link that allows the optimizer to serve RCEA load from either node. RCEA’s planning horizon is represented by five snapshot years (2028, 2030, 2035, 2040, and 2045) at hourly resolution, each treated as a representative investment period; the optimizer selects capacity for extendable Market resources and dispatches all resources simultaneously, subject to a system-wide CO₂ constraint (0 metric tons by 2045) and a capacity-persistence constraint requiring that once a resource is contracted or built, its capacity cannot decrease during its operating life.
PyPSA resembles RESOLVE in the sense that both are least-cost capacity-expansion and dispatch optimization tools operating over a multi-year planning horizon subject to policy and reliability constraints. PyPSA differs in some aspects because it uses specific contract economics to model take-or-pay obligations for both existing and potential resources, as opposed to a generalized levelized cost of energy approach. Regardless, they serve similar roles.
Clean System Power Calculator
13 The CSP calculator is a tool developed by the CPUC for LSEs to estimate GHG emissions associated with the IRP portfolios. As stated in the CSP Tool Documentation, “The core function of the CSP calculator is to assign emissions associated with the CAISO system’s dispatchable thermal generation and unspecified imports (“system power”) to LSEs based on how each LSE plans to rely on CAISO system power to meet its load on an hourly basis. The tool also calculates emissions from other generation sources that can be attributed to an LSE’s resource portfolio, including combined heat and power (CHP) and coal, as well as criteria pollutant emissions from biogas and biomass. The CSP tool relies on hourly dispatch profiles and results from the CPUC’s SERVM production cost and reliability model.” RCEA used data from the CSP calculator as inputs to its IRP modeling, specifically annual load volumes at the generator bus-bar and hourly generation profiles of specific technology types being evaluated. ii. Modeling Approach
Load Forecast
RCEA developed its IRP using its assigned load forecast in the IRP Requirements Ruling, which is the “Managed retail sales forecast” in the CSP calculator. Additionally, RCEA utilized the “Calculated demand at utility-scale generator bus-bar” in the CSP calculator to conduct its portfolio optimization modeling, which is about 8.8% higher than RCEA’s managed retail sales forecast. This ensured the portfolio accounted for transmission and distribution losses, minimized reliance on system power, and ensured conformance with the assigned GHG benchmarks. Both assigned load forecasts for 2028, 2030, 2035, 2040, and 2045 (“IRP model years”) are as follows in Table 1:
Table 1: RCEA’s Load Forecast for the IRP Model Years
Year Managed Retail
Sales Forecast (GWh)
Calculated Demand at
Generator Busbar (GWh)
2028 579 631
2030 647 705
2035 865 942
2040 1,041 1,133
2045 1,157 1,259
14 The Calculated Demand at Generator Busbar load forecast is about 8.8% higher than the Managed Retail Sales Forecast due to the inclusion of demand modifiers such as electrification load and BTM resources. Both load forecasts are significantly higher than RCEA’s internal load forecast which was submitted to the CPUC for consideration in 2025 and is based on RCEA’s recently declining load trend. RCEA is actively engaging the CEC to understand the assumptions behind the IEPR forecast, and bring the it more in alignment with RCEA’s internal load forecast for the next IRP cycle.
Load Shape
In developing its Preferred Conforming Portfolio, RCEA used a custom load shape rather than the default load shape from the CSP calculator. RCEA elected to use its own load shape to reflect the significant differences between its typical load profile and that of the CAISO system average. These differences are due to the geography of RCEA’s service territory and the demographics of its customer base. Humboldt County is at the northernmost latitude of CAISO’s territory and the majority of RCEA’s load within the county is located within ten miles of the coast where cooling loads are minimal year-round. RCEA’s 4,000-square-mile service territory is also primarily rural in nature, with the largest city containing a population under 30,000. These geographical and demographic differences from most of the state results in a load which is more akin to the Pacific Northwest than the rest of California, with a winter peak driven by lighting and heating needs, and little HVAC usage over the summer months. RCEA’s custom load shape results in a peak demand that is 22% to 26% (29 to 64 MW) lower than the peak demand of the default CAISO average load shape, depending on the modeling’s forecast year. RCEA’s custom load shape implies a winter peak that is 25% to 30% (24 to 40 MW) greater than the default winter peak, and a summer peak that is 39% to 43% (51 to 108 MW) lower than the default summer peak. The use of this custom load shape does not change RCEA’s total annual energy volumes for both load and load modifiers, and these volumes remain consistent with RCEA’s assigned load forecast.
Load-Proportional GHG Emissions Benchmark
15 Using the CSP calculator, RCEA assessed the emissions of its Preferred Conforming Portfolio against its load-proportional share of the 2030, 2035, 2040 and 2045 GHG emissions benchmarks, as assigned in the IRP Requirements Ruling and provided in Table 2: 8 Table 2: RCEA’s Assigned GHG Benchmarks
2030 2035 2040 2045
0.052 0.045 0.041 0.022
Compiling Specified and Generic Resources
To evaluate its IRP portfolio scenarios, RCEA initially compiled a list of the following contracted and candidate resources for the PyPSA Optimizer to select from:
• Currently and soon-to-be contracted generation and full-toll storage resources, both online and in-development;
• Specified geothermal resources to which RCEA has exclusive rights through CC Power’s Strategic Geothermal Initiative;
• Specified offshore wind capacity from the North Coast, Central Coast and CADEMO projects;
• Extended procurement of RCEA’s contracted local biomass facility, which currently expires in 2031;
• New development of a local small hydropower resource; • Candidate generic solar, onshore wind, conventional geothermal, enhanced geothermal, biomass and battery storage resources.
To identify the list of candidate specified and generic resources, RCEA referred to its Strategic Plan and the CPUC’s TPP Portfolio, as well as viable resource development opportunities RCEA is aware of. Prices and maximum capacity constraints were set for each candidate resource based on the CPUC’s Inputs and Assumptions Report 9 and RCEA’s internal procurement 8 IRP Requirements Ruling at 10.
9 https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M595/K085/595085015.PDF 16 experience and market intel. Hourly capacity factors for each resource type were pulled from the CSP calculator, to determine the generation profiles for all modeled resources, whether contracted or candidate.
Modeling Portfolio Scenarios
RCEA developed two scenarios for consideration by its Board of Directors: a Policy Portfolio and an Economic Portfolio. Both scenarios included RCEA’s currently and soon-to-be-contracted resources, and utilized the PyPSA Optimizer to fill the open energy position relative to RCEA’s assigned load forecast at the generator busbar. For the Economic Portfolio all non-contracted resources, whether specified or generic, were considered based on their economic performance and the Optimizer selected the least-cost best-fit resources to fill the open position. For the Policy Portfolio, several specified resources that were not selected in the Economic Portfolio, namely offshore wind and enhanced geothermal, were modeled as additional contracts instead of candidate resources based on economic performance. This resulted in slightly reduced open position for the Optimizer to fill, and slightly higher net cost for the Policy Portfolio.
RCEA input the results of each model run into the CSP calculator to check for compliance with the assigned GHG emissions benchmarks. Additional model runs were completed as necessary to optimize the portfolio and reduce reliance on system power, including adding storage capacity to reduce solar curtailment.
Economic Portfolio Value
RCEA considered the net cost of the portfolio modeling scenarios discussed above by using long-run economic performance forecasts of the various resources in each portfolio through 2045. Economic performance was modeled on an hourly basis with scaling to expected monthly production and is agnostic to long-run market fundamental views. This approach avoids temporal effects related to resource construction timing and captures the most important elements of a resource’s production curve relative to market value. Candidate resources are further evaluated for their RA value and renewable attribute value, culminating in a forward net value projection that is discounted to the present day. RCEA calculates a Total Cost to Serve 17 Load for each representative period as the sum of (1) take-or-pay obligations for every active resource, fixed or selected, including batteries, and (2) system power dispatch cost, divided by that period’s total load to produce an all-in $ /MWh figure. This provides period-by-period and horizon-average cost metrics ($/MWh) that can be compared directly across scenarios and against RCEA’s historical costs, without conflating the optimizer’s internal decision variable with RCEA’s actual financial exposure.
Confirming Reliability
RCEA used its assigned share of reliability need as the basis to forecast its RA obligations through the IRP study horizon. RCEA then evaluated whether the portfolio modeling scenarios provided sufficient long-term capacity to meet its assigned reliability need each year, using a combination of contracted and calculated Net Qualifying Capacity (“NQC”) and marginal Effective Load Carrying Capability (“ELCC”) values provided in the RDT. RA positions between 70% and 100% were targeted in each year to ensure the majority of its reliability need across the planning horizon would be provided by long-term contracts without excessive reliance on existing resources not yet contracted. RCEA then added enough short-term RA in years with outstanding open positions such that its total effective MW supply was equal to or greater than its reliability need in each year. Nine of the ten IRP years were over 100% hedged by long-term resources and thus didn’t require the addition of assumed short-term RA procurement.
Calculating GHG Emissions
RCEA calculated the emissions associated with the candidate portfolios described above, including its final Preferred Conforming Portfolio, using the Commission’s CSP calculator. In comparing the emissions associated with each candidate portfolio, where scenarios failed to comply or meet RCEA’s own emissions objectives, portfolios were modified to achieve compliance.
iii. Alternative Assumptions
The following alternative assumptions were utilized in the case of specific resources for which no pricing assumptions were provided in the CPUC’s Inputs and Assumptions Report:
18 • Existing Biomass – RCEA modeled continued procurement of the Humboldt Sawmill Company biomass plant located in its service area, beyond the current PPA expiration in 2031. Since this is not a new-build facility, the pricing in the CPUC’s Inputs and Assumptions Report is not applicable. RCEA forecasted a model price for this resource by extrapolating the current PPA price, which is indexed to California Consumer Price Index (“CPI”), over the IRP planning horizon based on recent historic average CPI rate of increase.
• Small Hydropower – Development of new-build, RPS-eligible hydropower is not contemplated in the CPUC’s IRP analysis, likely due to the small scale, limited potential and unique challenges associated with development of the resource type relative to other RPS technologies. However, small hydropower remains a viable resource in RCEA’s service area and is expressly contemplated in its Strategic Plan. Additionally, RCEA is aware of efforts underway to explore development of local small hydro resources by North Coast Tribes in their sovereign territories. No pricing for new small hydropower is available, so RCEA forecasted a model price for this resource by doubling the price for its existing small hydropower PPA as a proxy.
III. Study Results
a. Conforming and Alternative Portfolios
As required by the Commission, RCEA is submitting one Conforming Portfolio that achieves emissions equal to or less than its proportional share of the 8 MMT by 2045 GHG target. In addition to conformance with the “equal to or less than” GHG emissions requirement, this portfolio 1) is consistent with inputs and assumptions used by staff to develop the 2025-2026 TPP Portfolio, with alternative assumptions supported in Section II(b)(iii)., 2) utilizes RCEA’s assigned forecasts for energy load, peak demand and demand modifiers, 3) utilizes a custom load shape in the CSP calculator described in Section II(b)(ii)., and 4) conforms to RCEA’s annual reliability need in all years of the planning horizon. RCEA is not submitting any Alternative Portfolios for consideration.
RCEA’s 8 MMT Conforming Portfolio
19 The Policy Portfolio scenario described in Section II(b)(ii) is RCEA’s 8 MMT Conforming Portfolio.
The portfolio is summarized in Tables 3 and 4, which show total capacity by resource type and contract status, and the list of specific projects included in this portfolio, respectively. The tables include existing resources that RCEA owns or contracts with, consistent with definitions provided in the RDT, resources RCEA plans to contract with in the future, and new resources that RCEA plans to invest in.
Table 3: Total Capacity by Contract Status in RCEA’s 8 MMT Conforming Portfolio Resource Type Online Development Review Planned
Existing
Planned
New Total
Biomass 18 18 18
Small Hydropower 5.6 10 15.6
Onshore Wind 4 28.3 32.3
Offshore Wind 19.4 19.4
Geothermal 4.6 16.5 98.4 119.5
Solar 110.7 4 200 314.7
Battery Storage 99.4 59.9 159.3
RA-Only Storage or
Demand Response 46.9 46.9
Table 4: Specific Projects in RCEA’s 8 MMT Conforming Portfolio Resource Name Contract
Status
Contract
Capacity (MW) Description
Humboldt Redwood Online 18 Biomass co-generation facility in Humboldt County
Cove Hydroelectric Online 5.6 Run-of-river hydroelectric plant in Shasta County
Redwood Coast
Airport Microgrid Online 2.3
RCEA-owned solar PV plus lithium-ion
battery storage microgrid at Humboldt
County’s regional airport
Tierra Buena BESS Online 3 RA-only lithium-ion battery storage in Sutter County
Leapfrog DR Online 6 RA-only CAISO-wide demand response capacity
Sandrini Solar Online 100 Solar PV facility in Kern County Sandrini BESS Online 92 Lithium-ion battery storage facility in Kern County, co-located with Sandrini Solar
20 Resource Name Contract
Status
Contract
Capacity (MW) Description
Tumbleweed LDS Online 2.5
8-hour lithium-ion battery storage facility in
Kern County jointly procured through CC
Power
North Coast
Highway Solar Online 1.97 Feed-In Tariff solar PV facility in Humboldt County Foster Clean Power Online 7 Solar PV plus lithium-ion battery storage facility in Humboldt County
Resurgence I Online 12 RA-only lithium-ion battery storage in Sutter County
Sagebrush II Online 18 RA-only lithium-ion battery storage in Sutter County
Flycatcher Development 5.92 Lithium-ion battery storage facility in Humboldt County
Hatchery Road Development 3.96 Solar PV plus lithium-ion battery storage facility in Humboldt County
Paradigm Development 4 Wind repower facility in the Tehachapi area of Kern County
Dogwood Development 0.8 Nevada geothermal resource jointly procured through CC Power
Development Nevada geothermal resource jointly
procured through CC Power
Ormat Balance of
Supply Development
Multiple new geothermal resources in
Nevada and California jointly procured
through CC Power
Fish Lake Development 0.55 Nevada geothermal resource jointly procured through CC Power
Drifter Development 50 Lithium-ion battery storage facility in Ventura County
Willow Rock Development 3.1
RA-only advanced compressed air energy
storage facility in Kern County jointly
procured through CC Power
Mayacamas Review 1.4 California geothermal resource jointly procured through CC Power
EGX Pluth Ranch Review 7 Next-generation geothermal development jointly procured through CC Power
XGS Review 2.6 Next-generation geothermal development
jointly procured through CC Power
Atlantica Review 2.5 Next-generation geothermal development jointly procured through CC Power
Zanskar Review 3 Next-generation geothermal development jointly procured through CC Power
Humboldt Redwood
Renewal
Planned
Existing 18 Extended procurement of biomass co-generation facility in Humboldt County 21 Resource Name Contract
Status
Contract
Capacity (MW) Description
CADEMO Planned New 3 Offshore wind project in central coast State waters
North Coast OSW Planned New 10 Offshore wind capacity from Humboldt Wind Energy Area
Central Coast OSW Planned New 6.5 Offshore wind capacity from Morro Wind Energy Area
Local Small Hydro Planned New 10 Local small hydropower development in Humboldt or Trinity County
California Solar Planned New 200 Generic, in-state solar resource California Wind Planned New 100 Generic, in-state onshore wind resource Generic
Conventional
Geothermal
Planned New 120 Generic, out-of-state geothermal resource Generic Enhanced
Geothermal Planned New 26.2 Generic, in-state next-generation technology geothermal resource This portfolio includes a mix of online, in development and planned new resources, both contracted and not-yet-procured, with minimal reliance on planned existing resources which are not yet contracted. Approximately 50% of RCEA’s Conforming Portfolio is already contracted and either operational, in-development, or under review.
As demonstrated in Table 5, new resource procurement in RCEA’s 8 MMT Conforming Portfolio is generally consistent with the Commission’s 2025-2026 TPP Portfolio with updates as transmitted to CAISO and identified in 10. RCEA’s share of TPP Portfolio resources is calculated using its assigned managed retail sales forecast as a percent of the total assigned CPUC-jurisdictional retail sales forecast.
Table 5: 8 MMT Conforming Portfolio New Resources Compared to 2025-2026 TPP Resource Type
2025-2026 TPP
New Resource
Capacity (MW)
RCEA Share of
TPP New
Resources (MW)
RCEA 8 MMT
Conforming
Portfolio (MW)
Explanation of
Differences Between TPP
Share and 8 MMT
Conforming Portfolio
Biomass 200 1 0 Procuring from existing
resource; lack of new-
22 Resource Type
2025-2026 TPP
New Resource
Capacity (MW)
RCEA Share of
TPP New
Resources (MW)
RCEA 8 MMT
Conforming
Portfolio (MW)
Explanation of
Differences Between TPP
Share and 8 MMT
Conforming Portfolio
build procurement
opportunities
Geothermal 1,600 5 163
Pursuant to Strategic Plan
goals, IRP Procurement
Orders, and portfolio
economic modeling
Hydro (Small) - 0 10
Pursuant to Strategic Plan
goals and portfolio
economic modeling
In-State Wind 9,000 28 72
Pursuant to portfolio
economic modeling and
in lieu of out-of-state
wind
Out-of-State
Wind 15,700 49 0
Pursuant to Strategic Plan
to procure in-state
resources in lieu of out-of-state
Offshore Wind 4,500 14 19.4
Minimal difference;
pursuant to Strategic Plan
goals
Utility-Scale
Solar 61,800 193 200
Minimal difference;
pursuant to portfolio
economic modeling
Battery Storage
(4-hour) 15,700 49 72
Minimal difference;
pursuant to GHG emission
modeling
Battery Storage
(8-hour) 21,100 66 2.6
Pursuant to IRP
Procurement Orders;
procuring greater share of
4-hr battery storage
Pumped Hydro
Storage 800 2 0 Lack of procurement opportunities
Total 127,400 397 539
Conformance with RCEA’s
assigned load forecast
and GHG emissions
benchmarks
The differences between RCEA’s proportional share of the 2025-2026 TPP Portfolio and the new resource buildout contemplated in its 8 MMT Conforming Portfolio reflect RCEA’s portfolio modeling of economic resources necessary to meet its assigned load forecast while complying 23 with the GHG emissions targets, as well as RCEA’s Board-adopted goals for local resource development, to the extent technically feasible and economically prudent.
Consistent with Energy Division staff guidance, RCEA does not plan to procure exactly according to the timing and proportional share of the TPP Portfolio. This would be infeasible and imprudent for RCEA given its small size and thus small annual incremental resource shares. The resource timing outlined in RCEA’s Conforming Portfolio periodically layers in contracts of varying sizes to account for the economies of scale associated with larger projects, while recognizing some quantity of short-term procurement will be utilized to fill in and optimize the position as needed.
b. Preferred Conforming Portfolio
RCEA has adopted the 8 MMT Conforming Portfolio described in detail in Section III(a) as its Preferred Conforming Portfolio. The portfolio includes the procurement of the following new resources that are not yet contracted, the buildout of which is summarized in Figure 3:
• 10 MW Small Hydropower
• 10 MW North Coast Offshore Wind
• 9.5 MW Central Coast Offshore Wind
• 16.5 MW In-State Enhanced Geothermal Projects
• 26 MW Generic In-State Enhanced Geothermal
• 120 MW Generic Out-of-State Geothermal
• 200 MW Generic Large-Scale Solar
• 72 MW Generic In-State Onshore Wind
• 75 MW Generic Battery Storage
24 Figure 3: RCEA 8 MMT Preferred Conforming Portfolio New Resource Buildout The Preferred Conforming Portfolio provides for the following overall resource mix in 2045:
• 215 MW Solar
• 76 MW Onshore Wind
• 19.5 MW Offshore Wind
• 167 MW Geothermal
• 18 MW Biomass
• 10 MW Small Hydro
• 230 MW / 920 MWh Short-Duration Storage
• 3 MW / 24 MWh Long-Duration Storage
In accordance with PUC Section 454.51(b)(3), RCEA’s governing board has determined that the resource mix in this portfolio achieves “economic, reliability, environmental, security, and other benefits and performance characteristics that are consistent with the goals set forth in PUC Section 454.51(a)(1).” RCEA has determined that this Preferred Conforming Portfolio achieves the statutory and administrative requirements in PUC Section 454.52(a)(1), as demonstrated in the following portfolio characteristics and benefits.
25 (A) Meeting GHG Reduction Targets
RCEA’s Preferred Conforming Portfolio achieves results and performance characteristics consistent with the PUC Section 454.52(a)(1)(A) goal of meeting the state’s GHG reduction targets, as set by the Air Resources Board in conjunction with the Energy Commission and the Public Utilities Commission. The resultant GHG emissions from RCEA’s Preferred Conforming Portfolio are lower than its load-proportional share of the 8 MMT 2045 benchmark of 0.022 MMT CO2 equivalent. According to the CSP calculator, RCEA’s Preferred Conforming Portfolio would result in -0.153 MMT of CO2 equivalent in 2045, beating the benchmark by 0.175. (B) Procuring Renewable Energy Resources
RCEA’s Preferred Conforming Portfolio achieves results and performance characteristics consistent with the PUC Section 454.52(a)(1)(B) goal of ensuring that portfolios are composed of at least 60% eligible renewable resources by 2030. The portfolio contemplates increasing amounts of renewable energy each year until arriving at a portfolio of 100% PCC1 renewable resources by 2030.
(C) Serving Customers at Just and Reasonable Rates
RCEA’s Preferred Conforming Portfolio achieves results and performance characteristics consistent with the PUC Section 454.52(a)(1)(C) goal of fulfilling its obligation to serve its customers at just and reasonable rates. RCEA currently sets its rates according to PG&E’s generation rates, but is evaluating implementation of a cost-of-service rate structure. Based on the modeling described in Section II(b)(ii), RCEA’s Preferred Conforming Portfolio results in a Total Cost to Serve Load over the horizon average of $151.29/MWh. However, this figure is heavily driven by post-2030 investments in new generation technology. The 2030 benchmark cost is $109.74/MWh. RCEA will continue to evaluate new resource builds consistent with just and reasonable practice. The Preferred Conforming Portfolio meets the required de minimis carbon intensity at least cost given the resources available for selection from inputs and assumptions consistent with the 2025-2026 TPP Portfolio. (D) Minimizing Bill Impact
26 RCEA is committed to providing just, reasonable, and competitive rates that will not materially increase bills above what the customer would pay in the absence of RCEA’s CCA program. Since RCEA only controls the electric generation component of customer utility bills, it does not have discretion over the transmission, distribution, departing load, and non-bypassable charge components, which make up the majority of the bill. RCEA’s Preferred Conforming Portfolio achieves results and performance characteristics consistent with the PUC Section 454.52(a)(1)(D) goal of minimizing the impact of planned procurement on ratepayers’ bills. The portfolio consists primarily of renewable resources that have benefitted from increasing economies of scale over the past several years and have price projections that continue to drop in the foreseeable future. However, the portfolio also includes more expensive RPS resources such as offshore wind and geothermal, as RCEA recognizes the myriad other benefits of developing these resources, such as 1) diversifying its renewable power portfolio, 2) advancing emerging, next-generation technologies, 3) workforce development and other associated community benefits, and 4) contributions to grid reliability. The above-market cost of these resources is a tradeoff for their time-of-generation benefits, but RCEA’s financial modeling supports their inclusion in the portfolio.
Also described in Section II(b)(ii), RCEA evaluated two potential portfolio scenarios. The selected Preferred Conforming Portfolio was chosen for its resource diversity, cost, reliability contribution, alignment with RCEA’s Strategic Plan, and likelihood for implementation. The Preferred Conforming Portfolio is projected to be the more expensive of the two scenarios evaluated. However, by providing a more diversified portfolio it reduces risk associated with any one technology and more fully achieves energy resource diversification goals stated in RCEA’s Strategic Plan.
(E) Ensuring System and Local Reliability
RCEA will continue throughout the IRP planning horizon to procure RA in keeping with Commission year-ahead and month-ahead requirements, as well as contracting for long-term incremental capacity in keeping with existing and any future Commission reliability decisions.
RCEA’s Preferred Conforming Portfolio includes resources already contracted specifically to 27 meet Commission reliability decisions to date, as well as expected capacity procurements pursuant to these obligations.
RCEA’s Preferred Conforming Portfolio achieves results and performance characteristics consistent with the PUC Section 454.52(a)(1)(E) goal of ensuring system and local reliability, as demonstrated by RCEA’s total supply exceeding its reliability need in the RDT. (F) Long-Term Contracting
RCEA’s Preferred Conforming Portfolio achieves results and performance characteristics consistent with the PUC Section 454.52(a)(1)(F) goal of at least 65 percent of the LSE’s RPS procurement for each compliance period shall be from its contracts of 10 years or more in duration or in its ownership or ownership agreements for eligible renewable energy resources.
RCEA achieved compliance with this mandate in RPS Compliance Period 4, and with additional facilities that have come online since then plus those contemplated in the Preferred Conforming Portfolio, RCEA expects to exceed this mandate in current and future Compliance Periods.
(G) Strengthening the Transmission and Distribution System and Local Communities RCEA’s Preferred Conforming Portfolio places strong emphasis on developing new, diverse, and firm resource capacity in Northern California, through continued existing biomass procurement, offshore wind, enhanced geothermal and small hydropower development, thereby achieving results and performance characteristics consistent with the PUC Section 454.52(a)(1)(G) goal of strengthening the diversity, sustainability, and resilience of the bulk transmission and distribution (“T&D”) system, and local communities.
In recent decades, generation capacity in RCEA’s service territory consisted mainly of PG&E’s natural gas-fired Humboldt Bay Generating Station (“HBGS”), three biomass power plants with intermittent operating histories, and a handful of small, run-of-the-river hydropower plants operated seasonally. RCEA’s Preferred Conforming Portfolio plans for several additional new clean resources to be built within its service area or the greater region, several of which have come online in recent years. These planned resources, including offshore wind, enhanced geothermal, co-located and standalone solar and energy storage, and small hydro, will diversify 28 energy sources meeting local load and spur T&D improvements to the North Coast. Particularly in the case of projects including energy storage, these new resources will contribute to resilience for local communities by potentially keeping segments of the local grid energized under conditions where outages might otherwise occur.
In particular, large-scale development of offshore wind off the Humboldt Coast will require development of new bulk transmission infrastructure that will benefit RCEA’s service area by increasing capacity for both import and export of energy, overcoming the currently limited transmission connection between Humboldt County and the rest of the state. Transmission upgrades may also have the benefit of resolving current transmission and distribution constraints impeding interconnection of new load and distributed generation within the county, as described further in Section III(m).
(H) Enhancing Distribution Systems and Demand-Side Energy Management RCEA’s Preferred Conforming Portfolio achieves results and performance characteristics consistent with the PUC Section 454.52(a)(1)(H) goal of enhancing demand-side management (“DSM”). The assigned demand modifiers for energy efficiency, building and vehicle electrification, and BTM customer solar are incorporated into RCEA’s Preferred Conforming Portfolio via demand-side assumptions in the CSP calculator from the CEC’s IEPR demand forecast. A summary of these load modifiers is presented in Table 5.
Table 5: RCEA CSP Summary of Demand Modifiers
Demand Modifers (GWh) 2028 2030 2035 2040 2045
Managed Retail Sales Forecast (assigned to LSE) 579 647 865 1,041 1,157 Baseline Demand, non-C&I 296 303 345 383 406
Baseline Demand, C&I 350 357 406 451 478
Electric Vehicle Load 41 71 169 255 319
Building Electrification 19 36 84 108 128
Energy Efficiency (17) (21) (30) (32) (34)
Data Center Load 31 51 78 88 94
Climate Change Impact Load Increases 2 3 5 8 11
Climate Change Impact Load Decreases 0 (1) (1) (2) (3)
BTM PV (91) (96) (116) (129) (142)
BTM Storage 1 1 2 2 3
Demand (at generator busbar) 646 660 751 834 884
29 (I) Minimizing Localized Air Pollutants with Early Priority on Disadvantaged Communities RCEA’s Preferred Conforming Portfolio achieves results and performance characteristics consistent with the PUC Section 454.52(a)(1)(H) goal of minimizing localized air pollutants and other GHG emissions with early priority on disadvantaged communities, since it relies primarily on renewable generation and would have extremely low GHG and localized air pollution emissions. The portfolio does contemplate continued existing biomass power that, while an RPS resource, does produce some local emissions. However, the use of existing generating infrastructure and community benefits including jobs and a means of disposing residual material from local forest products manufacturing make biomass a preferred resource for communities served by RCEA. Air pollutant implications of this are discussed further in Section III(d). Lastly, RCEA’s Preferred Conforming Portfolio minimizes RCEA’s reliance on unspecified system power, instead opting for renewable generation procurement and development whenever feasible. RCEA’s Preferred Conforming Portfolio will not include any contracts for new natural gas resources or re-contracting with terms of five years or more for existing natural gas resources. Also discussed in Section III(d) are implications for disadvantaged communities (“DACs”). RCEA’s service area includes lands under the control of two federally recognized Tribes, and no other DACs according to CalEnviroScreen 4.0 (“CES”). (J) Maintaining a Diverse Portfolio of Energy Resources RCEA’s Preferred Conforming Portfolio achieves results and performance characteristics consistent with the PUC Section 454.52(a)(1)(J) goal of maintaining a diverse portfolio of energy resources, including eligible energy resources procured by the Department of Water Resources.
The portfolio includes solar, storage, onshore wind, offshore wind, geothermal, biomass and small hydro resources.
c. GHG Emissions Results
RCEA used its share of the 2045 8 MMT GHG emissions benchmarks to determine the emissions compliance for its Preferred Conforming Portfolio, as described in Section III(d). RCEA’s Preferred Conforming Portfolio would result in GHG emissions that are 527% lower than its 30 assigned 2035 benchmark and 822% lower than its assigned 2045 benchmark, as shown in Figure 4.
Figure 4: RCEA Preferred Conforming Portfolio 25 MMT CSP Calculator Results RCEA used a custom hourly load shape for analyzing GHG emissions in the CSP calculator. RCEA utilized a long-term load forecast covering the years 2026-2033 that is based on RCEA’s historical settlement quality meter data (SQMD) from January 2018 through December 2025.
However, RCEA scales this forecast to match the total annual energy value assigned in the IEPR process by the CPUC. RCEA requires a custom load shape
d. Local Air Pollutant Minimization and Disadvantaged Communities i. Local Air Pollutants
Table 6 shows 2035 and 2045 criteria air emissions associated with RCEA’s Preferred Conforming Portfolio as estimated by 25 MMT version of the CSP calculator, in metric tons per year.
Table 6: 25 MMT Preferred Conforming Portfolio Criteria Air Pollutants Pollutant 2035 2045
PM 2.5 16.5 10.8
31 Pollutant 2035 2045
SO2 10.4 9.9
NOx 54.0 39.2
ii. Focus on Disadvantaged Communities
CalEnviroScreen 4.0’s mapping tool shows that no part of RCEA’s service territory includes the state’s top 25% of impacted census tracts, or census tracts with the highest pollution burden.
However, RCEA’s service area includes two Disadvantaged Communities (DAC) based on CalEPA’s designation, which are the federally recognized Yurok and Hoopa Reservations,
10. In
addition to these two SB 535 Disadvantaged Communities, the following federally recognized Tribes have lands within Humboldt County 11:
• Bear River Band of the Rohnerville Rancheria
• Big Lagoon Rancheria
• Blue Lake Rancheria
• Cher-Ae Heights Indian Community of the Trinidad Rancheria • Trinidad Rancheria
• Karuk Tribe
• Wiyot Tribe
Of the tribes within RCEA’s service area footprint, the Hoopa Valley Tribe experiences particularly high air pollution due to its location within a high fire threat district. 12 Consequently, the Hoopa Valley Tribe is also subject to frequent PSPS events and power outages. RCEA has been supporting a coalition of four local Tribes to address . Additionally, RCEA partnered with several rural fire stations
RCEA recognizes poverty and low household income are widespread in Humboldt County, as shown by other criteria beyond those used in CES. For example, of RCEA’s ~62,000 electric 10 https://oehha.ca.gov/calenviroscreen/sb535
11 List of Federally Recognized Tribes, Indian Health Service, January 28, 2022 12 Office of the State Fire Marshal, CalFire, State Responsibility Area, November, 2007 (most recent data available) 32 accounts, approximately 15,000 are residential CARE-eligible accounts. RCEA is dedicated to minimizing local air pollution and recognizes that lower income residents can be the most vulnerable to air pollution and other adverse environmental impacts, generally. RCEA also has a Racial Justice Plan, one of the goals of which is to ensure energy justice in power procurement and energy resource development.
RCEA’s Preferred Conforming Portfolio includes continued procurement of the Humboldt Redwood biomass plant. Some communities served by RCEA are exposed to, or are at risk of exposure to, criteria pollutants emitted by the local biomass plant. This concern is considered by RCEA’s Board in weighing this existing local RPS resource against the cost of developing new, local renewable resources, or procuring RPS resources from outside RCEA’s service area. In the Board’s deliberations to date, the need to ensure RPS and SB 350 compliance, the economic and workforce benefits, and need for local sawmill waste disposal have to date outweighed the GHG and air quality impacts of local biomass procurement.
The Humboldt Redwood biomass plant is the only specified source of NOx, SO2 or PM2.5 emissions in RCEA’s Preferred Conforming Portfolio. Since the portfolio contemplates steady biomass procurement from the same facility, with the facility’s current contract with RCEA running until 2031 and this contract assumed in RCEA’s Preferred Conforming Portfolio to be extended throughout the IRP planning horizon, the resulting criteria pollutants are expected to remain constant over time as is shown in the CSP calculator results. RCEA and HSC have a memorandum of understanding (“MOU”) that calls for annual reporting on fuel use and sources, emissions, and information regarding HSC’s consideration of other potential feedstock uses that could result in reduced air quality impacts. These impacts are reviewed and discussed annually by staff with RCEA’s Biomass Technical Advisory Group, Community Advisory Committee, and Board of Directors.
RCEA achieved 100% clean and renewable energy on an annual basis in 2025 and plans to increase its renewable target each year until achieving 100% renewable energy on an annual basis in 2030. RCEA’s Preferred Conforming Portfolio does not include energy contracts for gas generators, including those located within or adjacent to DACs. The portfolio also minimizes the use of unspecified system power, reducing its potential indirect reliance on gas generators that 33 have an impact on DACs. The portfolio does, however, continue to rely on unspecified system power during hours when generation or storage supply isn’t sufficient to meet load, as well as on combustion gas capacity to meet the balance of its RA needs in some IRP planning years.
However, RCEA aims to reduce its reliance on unspecified system power and gas-based RA over the IRP planning horizon.
e. Cost and Rate Analysis
A core part of RCEA’s mission is to offer affordable generation rates to its customers. RCEA currently sets its generation rates based on those offered to bundled customers by PG&E, and has delivered $5.5 million in cumulative ratepayer savings to its customers since CCA program launch. Like many other CCAs, RCEA does not currently use a traditional bottom-up, cost-of-service ratemaking model, but is evaluating transitioning to this structure in the near term.
Given the construct in California where CCAs operate within IOU service areas and must compete with the IOU for rate-sensitive customers who can opt out of CCA service at any time, RCEA has historically set its rates at a fixed percentage relative to the IOU’s corresponding rates, taking the PCIA and other departing load charges into account. The intent is to provide rate discounts to customers when the budget allows during fiscal years there is a forecasted positive net revenue, while ensuring costs are covered, including maintaining financial reserves in compliance with RCEA’s Reserve Policy 13. For fiscal years that are forecasted to result in negative net revenue, RCEA considers several temporary cost-saving or revenue-generating measures to maintain financial stability, including 1) reducing its reserve target to the minimum level contemplated in its Reserve Policy, 2) raising customer generation rates (plus departing load charges including the PCIA) above the IOU’s rates while still ensuring affordability, and 3) reducing its voluntary renewable or carbon-free targets, in the most extreme case down to levels required to maintain RPS compliance.
To ensure long-term financial stability, RCEA may make a strategic decision to move to a cost-of-service rate structure in the future rather than a fixed differential from IOU rates, but in any 13 https://redwoodenergy.org/key-documents/
34 case, will continue to provide customer rates that are just and reasonable. RCEA’s Preferred Conforming Portfolio has been designed to keep power procurement costs at a level that will support this objective. , RCEA’s approach to IRP portfolio modeling, discussed in Section II(b)(ii), heavily emphasized economic optimization to support affordability, with policy considerations influencing a relatively small portion of the portfolio. The analysis was informed by forward price projections generated as described in Section II(b). In general, RCEA sought to balance the need to procure resources with enough lead time to meet its LSE-specific energy position and the Commission-identified overall system need for new resources. The estimated total cost to serve load over the five IRP model years is $706 million (2024 dollars), 6% of which is attributable to above-market offshore wind and enhanced geothermal resources, which were included in the portfolio for strategic policy purposes. RCEA’s economic analysis, summarized in Table 7, supports inclusion of these resources in the Preferred Conforming Portfolio, because their marginal above market costs can be absorbed over time with reasonable rate adjustments.
Table 7: Preferred Conforming Portfolio Cost to Serve Load IRP Model Year Cost to Serve Load
($/MWh)
2028 $90
2030 $110
2035 $166
2040 $182
2045 $167
RCEA’s Preferred Conforming Portfolio is diverse in both technology type and operational timing, seeking to both capture current opportunities for development while looking ahead to further cost-effective resource buildout. To ensure that its Preferred Conforming Portfolio is cost-effective, RCEA evaluated the incremental value of each resource relative to its current portfolio. The RCEA Preferred Conforming Portfolio meets reliability and emissions requirements while representing a clear net economic benefit to RCEA. 35 f. System Reliability Analysis
RCEA’s Preferred Conforming Portfolio is reliable and contributes RCEA’s fair share to system reliability. To confirm this, RCEA assessed the portfolio based on annual RA position relative to its assigned reliability need, total seasonal generation, and hourly generation during system peak hours. For total generation, RCEA’s Preferred Conforming Portfolio is expected to generate 258-320% of RCEA’s forecast load in the summer months (June through October) and 175-231% in the non-summer months (November through May) during the IRP model years.
During system peak hours, RCEA’s Preferred Conforming Portfolio is expected to provide up to 1,523% of RCEA’s own forecasted local demand in summer months of the IRP model years. In the winter and shoulder months, the Preferred Conforming Portfolio is expected to generate up to 1,610% of RCEA’s forecast demand during forecasted system winter peaks.
RCEA intentionally developed its Preferred Conforming Portfolio to exceed its forecasted need in the summer months, given the summer-peaking nature of California’s broader electric system. It is expected that the portfolio could provide much-needed reliability to the broader grid during these critical months (assuming sufficient transmission upgrades) and, likewise, RCEA’s service territory could utilize some amount of system power during its own winter peak when demand is low in other parts of the state. Upgrades to transmission infrastructure are needed to maximize the contribution to system reliability by capacity resources developed in the Humboldt Local Capacity Area, such as offshore wind, given the transmission-constrained nature of the region.
The effective capacity of RCEA’s Preferred Conforming Portfolio is provided in Figure 6 and Table 8 from the RDT. Figure 6 shows effective capacity by resource type and Table 8 shows reliability need, supply by contract status, and net capacity position for all study years. 36 Figure 6: RCEA Reliability Need by Resource Type
Table 8: Load and Resource by Contract Status
As demonstrated above, RCEA’s Preferred Conforming Portfolio meets the perfect capacity equivalent standard defined by Energy Division staff in all IRP years. In nineteen of the twenty IRP planning years, the effective capacity from long-term RCEA’s contracted and planned resources exceeds its managed reliability need. In only 2035, RCEA filled the open position of its assigned reliability need with a short-term RA contract from generic large hydro capacity. This demonstrates that RCEA’s preferred resource selections work together to effectively and reliably integrate a renewables-heavy portfolio while reducing reliance on existing fossil resources, thus meeting and exceeding RCEA’s share of any systemwide renewable integration resource requirement.
g. Existing Resource Planning
In developing its Preferred Conforming Portfolio, RCEA aimed to reduce reliance on uncontracted existing resources and on system power over the IRP planning horizon. The 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 LSE reliability need (MW) 86 88 90 83 76 80 83 86 89 93 97 102 106 111 116 120 124 128 132 137 ELCC by contract status (effective MW)
Online 170 164 151 109 67 63 60 54 49 47 48 49 49 50 38 36 35 35 35 16 Development - 6 9 8 6 18 17 16 16 15 15 15 15 15 15 15 15 15 15 15 Review - - - - 8 11 11 11 13 13 13 13 13 13 13 13 13 13 14 14 PlannedExisting - - - - - - - - 4 - - - - - - - - - - - PlannedNew - - - - - 1 1 1 1 142 143 144 145 145 168 169 170 170 171 170 BTM PV 4 4 4 4 4 5 5 6 6 7 7 8 8 9 10 9 9 9 9 8
LSE total supply (effective MW) 174 174 165 122 86 97 95 88 89 224 226 229 231 233 244 243 243 243 243 224 Net capacity position (effective MW) 88 87 75 38 9 17 12 2 0 132 129 127 124 122 128 123 119 115 110 87 37 following existing resources, which have contract statuses of “online” and “planned existing” in the RDT, are included in the portfolio:
1. Long-term energy purchase contracts and an owned generating resource
2. Long-term capacity purchase and sales contracts
3. Short-term procurements through 2029 from existing generic large hydro
4. Extension of the Humboldt Redwood biomass contract from 2031 to 2045 The first two groups of existing resources do not present risk of non-availability for RCEA’s portfolio because they are already procured through executed contracts. Some of these resources were just brought online in the last couple years. Risk associated with reliance on short-term procurement from existing generic large hydropower resources due to drought and declining snowpack is discussed in Section III(i). Competition with other LSEs is also a factor for this resource, including those within California and across the greater WECC as other states adopt and ramp up clean energy goals. Given RCEA’s small load relative to other LSEs, declining carbon-free procurement targets, and ability to secure sufficient supply in the past, the carbon-free volumes shown in its Preferred Conforming Portfolio are reasonable, regardless of competition with other LSEs. However, given that procurement of existing large hydro has little to no incremental climate benefits, RCEA aims to reduce reliance on this resource over the next several years, and to phase it out completely from its portfolio by 2030.
There is some risk associated with a contract renewal for the Humboldt Redwood biomass facility, should RCEA’s Board elect to renew before the current delivery term expires in 2031.
RCEA and the plant owner have an established, positive working relationship and the resource is located in RCEA’s service territory. However, despite continued investment in upkeep and modernization of the plant by its owners, it has reached the typical lifespan of thermal biomass plants.
Table 10 shows a comparison of the amounts of existing resources included in RCEA’s 2026 8 MMT Preferred Conforming Portfolio to those included in its 2022 25 MMT Preferred Conforming Portfolio, in terms of maximum annual energy contribution throughout the 38 respective IRP horizons. Excluded from the table are resources that have become operational since RCEA’s 2022 IRP submission. The portfolio reliance on existing resources has significantly reduced from 2022 to 2026.
Table 10: Existing Resources in RCEA’s Preferred Conforming Portfolio Existing
Resource Type
2026 8 MMT PCP
(GWh/year)
2022 25 MMT
PCP (GWh/year)
Biomass 80 100
Large Hydro 130 (to be phased
out by 2030) 200
Small Hydro 15 10
Total 520 310
The existing biomass and small hydro resources in RCEA’s 2026 8 MMT Preferred Conforming Portfolio are the same as those that were shown in its 2022 25 MMT Preferred Conforming Portfolio, with updated generation assumptions. The only significant difference between the two portfolios in terms of existing resource reliance is a reduction in expected large hydro purchases, in keeping with RCEA’s declining carbon free procurement targets, shown in Table
11. h. Hydro Generation Risk Management
RCEA plans to phase out large hydropower procurement by 2030, pursuant to its Board-adopted goal to procure 100% renewable energy on an annual basis by 2030. Relevant procurement targets during the interim period are shown in Table 11.
Table 11: RCEA’s Procurement Targets
2026 2027 2028 2029 2030
Renewable 62% 68% 76% 84% 100%
Carbon Free 38% 32% 24% 16% 0%
In developing the portfolio, RCEA took several steps to manage the risk of reduced hydropower availability due to in-state drought. Specifically, RCEA limited its reliance on large hydro to only the first IRP model year of 2028, in recognition that once new RPS resources in the portfolio are fully developed they will generate sufficient energy to meet RCEA’s load. 39 Compared to RCEA’s 2022 IRP portfolio, RCEA’s 2026 Preferred Conforming Portfolio relies on less large hydropower, as shown in Table 10. The Preferred Conforming Portfolio also relies less on in-state hydroelectric generation, favoring import of this resource from the larger WECC region where climate and drought impacts aren’t yet taking as severe of a toll on the hydro resources as in California. RCEA is cognizant that out-of-state hydropower will face the same challenges from climate and drought impacts over time given warming temperatures and the potential for reduced snowpack in the long run. RCEA believes its strategy will avoid exposure to significant impacts from these risks over time as it will continue to substitute new renewable resources for legacy hydropower. It is likely that RCEA will not be reliant on existing hydropower by the time climate risks severely hamper its availability.
The only in-state large hydropower included in the portfolio is a small amount from PG&E’s Carbon-Free Allocation of PCIA resources. RCEA will look to further reduce its use of large hydro over time as newer generating technologies become less costly, and development of planned resources progresses. RCEA has robust environmental goals that it would prefer to meet with new (and ideally local) renewables. Nevertheless, RCEA must balance that preference with the commitment it has made to pursuing near-term environmental goals that necessitate the continued use of large hydropower in the near term.
At the same time, RCEA recognizes the important role that small, run-of-river RPS-eligible hydropower, both existing and new projects, can play in the portfolio. In 2019, RCEA added a 15-year contract with the existing 5.6 MW Cove hydro project to its portfolio, which began delivering RPS-eligible power to RCEA in early 2020. RCEA has also engaged a consultant to investigate potential for development of new RPS-eligible hydro projects in Humboldt and Trinity Counties, as a first step in development of this resource included in RCEA’s Preferred Conforming Portfolio. Although this investigation into small hydro development was recently paused during the pandemic, RCEA plans to pick up on these efforts in the coming years, as discussed in Section IV(a)(v).
i. Long-Duration Storage Planning
In D.21-06-035, D.23-02-040 and D.26-02-057 (“IRP Procurement Orders”), the CPUC has identified the need to bring online 1,000-2,500 MW of long-duration energy storage (“LDS”) net 40 qualifying capacity between 2028 and 2032. RCEA’s share of the LDS procurement requirement is 3-8 MW. RCEA is currently meeting this requirement with the following two contracts through California Community Power (“CC Power”), a joint procurement agency comprised of nine CCAs:
• Tumbleweed is an 8-hour lithium-ion battery storage project, with a nameplate capacity of 75 MW/552 MWh, for which RCEA’s entitlement share is 3.62% or 2.72 MW, and an expected NQC of 1.95 MW. This project achieved COD on June 1, 2026 with a delivery term of 15 years.
• Willow Rock is an advanced compressed air energy storage project with a nameplate capacity of 50 MW/400 MWh, for which RCEA’s entitlement share is 6.2% or 3.1 MW, with an expected NQC of 1.64 MW. This project’s guaranteed COD is December 31, 2030 with a delivery term of 20 years.
j. Clean Firm Power Planning
The IRP Procurement Orders identify a need of 1,000-2,500 MW of incremental capacity delivered by 2028-2032 from “clean firm generation (with an annual capacity factor of at least 80 percent) resources that are not subject to use limitations or are weather dependent. The […] resource […] must be a generating resource, not storage, able to generate when needed, for as long as needed, and may not have any on-site emissions, except if the resource otherwise qualifies under the Renewables Portfolio Standard program eligibility requirements.” 14 As with the CPUC’s LDS procurement requirement discussed in Section III(j) above, RCEA elected to meet these requirements via joint procurement with other CCAs through CC Power. RCEA’s share of the FCR procurement requirements are 3-8 MW, which are currently being met with the following projects contracted through CC Power:
14 2022 IRP narrative template: https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/integrated-resource-plan-and-long-term-procurement-plan-irp-ltpp/2022-irp-cycle-events-and-materials/narrative-template.docx 41 • Fish Lake is a conventional geothermal project in Esmeralda County, NV with a nameplate capacity of 16.8 MW, for which RCEA’s entitlement share is 0.47 MW. This project’s expected COD is on or about July 1, 2027 with a delivery term of 20 years. • Dogwood is a conventional geothermal project in Imperial County, CA with a nameplate capacity of 25 MW, for which RCEA’s entitlement share is 0.8 MW. This project’s expected COD is September 1, 2027 with a delivery term of 20 years. • is a conventional geothermal project in Imperial County, CA with a nameplate capacity of MW, for which RCEA’s entitlement share is MW. This project’s expected COD is with a delivery term of 20 years.
Ormat Balance of Supply is a portfolio of yet-to-be-identified projects with a nameplate capacity of to MW, for which RCEA’s entitlement share is 3.2% of the developed capacity.CC Power GEODE Agreements
CC Power has played a pivotal role in driving procurement of geothermal capacity to meet the state’s future clean firm energy needs, demonstrated by its leadership in contracting the first new geothermal resources following release of the first IRP Procurement Order. CC Power recently entered into Geothermal Exploration, Offtake and Development Engagement (“GEODE”) agreements with three geothermal developers with innovative approaches to development targeted at unlocking in-state geothermal capacity at scale. RCEA considers these proactive relationships between offtakers and industry that CC Power is building as pivotal in overcoming the commercial and infrastructure challenges geothermal opportunities face.
Additionally, as a joint procurement entity representing 30,000 GWh of collective annual load, CC Power is able to engage with a larger diversity of developers and opportunities with different risk profiles than what could be pursued by an individual load serving entity.
RCEA’s IRP includes its participation in CC Power’s GEODE agreements, which are expected to deliver MW of total capacity in the early 2030s. The GEODE agreements are principally focused on development opportunities in Northern California that both avoid import constraints and directly offset power costs for CC Power’s members. CC Power has coordinated with its GEODE partners in representing expected development opportunities in the IRP. 42 Atlantica and XGS are
planning to deploy advanced closed-loop technology, which both enables development beyond the geologic constraints of conventional hydrothermal development and minimizes water requirements. Closed-loop technology has been demonstrated in the field and recently through commercial development in Germany. Through its GEODE agreement, Zanskar is applying its unique capabilities leveraging artificial intelligence and modeling to discover new hydrothermal systems.
The GEODE
projects are represented with online dates in the early 2030s but could be accelerated if transmission is readily available. GEODE projects are reported as “Review” status in the RDT to reflect the active commercial discussions between CC Power and developers on specific project opportunities.
CC Power Enhanced Geothermal System (EGS) Capacity
RCEA’s IRP also includes its participation in CC Power’s engagement with a developer of a near-field MW enhanced geothermal system (EGS) project in CC Power is currently under exclusivity for this project, which has site control and is planning to build upon Fervo Energy’s success in applying EGS technology to development in Nevada and Utah. This project is represented with an online date in 2033 but could be accelerated if transmission is made readily available. This project is also reported as “Review” status in the RDT given the advanced nature of commercial discussions.
RCEA’s IRP includes its early-stage participation in CC Power’s engagement with regarding their project. CC Power and the developer have nearly reached terms on an exclusivity agreement and have exchanged contract redlines for the project. The project will be developed in but faces significant development hurdles including sizeable network upgrade costs and the need for additional on-site equipment to manage non-condensable gases produced during generation. 43 CC Power Strategic Geothermal Capacity Coordination
RCEA has coordinated with CC Power on representing geothermal capacity needs beyond the opportunities described above. Collective, CC Power entities are anticipating nearly 500 MW of additional geothermal development need to meet 2045 needs. A key challenge with geothermal development is that even with next-generation technologies, the best opportunities are locationally constrained. Accordingly, it’s critical that transmission is proactively planned to areas that are commercially viable for both developers and offtakers. CC Power strongly discourages the Commission from taking the default approach of mapping resource potential to areas with sufficient transmission capacity and instead work to support infrastructure that provides access to high-quality resource areas as recommended by American Clean Power.
In the interest of providing a consistent indication of development areas with both high-quality resources and commercial offtake interest, CC Power members have taken a methodical process to mapping and representing long-term geothermal needs. First, CC Power has leveraged one of the best available datasets on next-generation geothermal potential: supply curves from Wilson Ricks and Jesse Jenkins’ May 2025 study on national-scale adoption of EGS .
The Ricks & Jenkins study leverages the recent Stanford thermal modeling already used by the Commission, but also specifically characterizes near-field EGS resources—which are likely to be the first and most economical projects to be developed. CC Power applied both technological and economic filters to the supply curve data (depth <= 4.5 km, temperature <= 275C, inferred LCOE <= $100/MWh, project capacity > 50 MW). Data points that met CC Power’s filter criteria are represented as the red dots in Figure 7.
44 Figure 7. CC Power Strategic Geothermal Mapping
Using the filtered data, CC Power identified clusters of opportunities with distinct transmission needs: West North Bay, East North Bay, Humboldt, Shasta, Klamath, Pit River, Surprise Valley, Lassen, and Imperial Valley (see colored polygons in Figure 7). CC Power members strongly prefer resources in CAISO due to import capacity constraints, and accordingly did not carry Imperial Valley, Klamath, and Shasta further in the analysis. Although Surprise Valley and Lassen are currently outside the CAISO, CC Power is encouraged by the 2026-27 focus on adding import capacity to the Hilltop substation in Northeastern California and sees a lot of synergies with creating better access to Northern Nevada resources and in-state wind.
Based on the supply curve filtering, the six remaining areas of interest individually represent 0.8 to 13.5 GW each of theoretical capacity. CC Power has represented its interest using two tiers:
the East North Bay and West North Bay with 150 MW of total interest (out of 10+ GW theoretical capacity each) and the other four areas with 50 MW of interest (out of 0.8 to 1.6 GW of theoretical capacity each). RCEA’s IRP includes its share of these opportunities with a 45 substation designated that is indicative of the resource area’s transmission needs. Given their pre-commercial nature, these projects are listed as “PlannedNew” but flagged for retention priority given the need to proactively plan transmission. CC Power will continue developing relationships with industry to further commercialize this capacity. k. Non-CAISO, including Out-of-State, Wind Planning
The 2025-2026 TPP calls for 15.7 GW of new out-of-state wind generation (“OOS wind”) to be operational by 2045. RCEA’s PCP does not contain any OOS wind resources. As a small LSE with goals to procure as much of its energy and capacity within California as close to its service area as possible, OOS wind resources are not part of RCEA’s procurement strategy. In lieu of OOS wind, RCEA plans to contract the wind capacity contemplated in its PCP from in-state, onshore repower and offshore resources. Additionally, CAISO’s import capability allocation process for securing rights to OOS capacity presents more risk in these transactions than RCEA can bear, unless mandated to procure resources that are only available at reasonable cost outside of CAISO. Consequently, RCEA does not intend to initiate any OOS wind procurement in this or subsequent IRP cycles.
l. Offshore Wind Planning
RCEA has been engaging on offshore wind development since 2018, given its proximity to the Humboldt Wind Energy Area as designated by the Bureau of Ocean Energy Management (“BOEM”). While BOEM’s efforts are on hold due to the federal administration’s moratorium on offshore wind leasing activities in federal waters, RCEA has continued to engage on offshore wind development in state waters by supporting CADEMO, a proposed floating offshore wind project that would be located in state waters off Lompoc. Recent efforts include advocating for the 2025-2026 and 2026-2027 state budgets to include funding for CADEMO, and agreeing to provide a short-term bridge loan to allow the project to maintain its place in PG&E’s interconnection queue, which wasn’t eventually needed.
46 One of the two portfolio scenarios RCEA analyzed in its IRP modeling includes offshore wind resources which eventually became its Preferred Conforming Portfolio. RCEA quantified offshore wind capacities from the Humboldt and Morro Wind Energy Areas based on its AB 1373 Central Procurement Entity allocation of 27 MW, scaled down to reflect a 4.5 GW buildout scenario contemplated in the 2025-2026 TPP Portfolio, rather than 7.5 GW buildout under AB 1373.
Developing and procuring offshore wind has been an integral part of RCEA’s strategic resource planning for many years, dating back to the RePower Humboldt Technical Study, a 2013 study funded through the California Energy Commission’s (“CEC”) Renewable Energy Secure Community Program. The benefits of offshore wind in RCEA’s Preferred Conforming Portfolio include the resource’s complementary generation profile to solar and other renewables in the planned portfolio, as well as its proximity to RCEA’s load and thus reduced basis risk assuming the resource is interconnected in or near Humboldt. Beyond the portfolio benefits, development of this resource has numerous benefits for RCEA’s service area including workforce and economic development, and port infrastructure revitalization spurred by the potential establishment of an offshore wind manufacturing hub at Humboldt Bay. Additionally, the resource may have less negative impact on the local community than local renewable energy alternatives such as onshore wind or even large-scale solar development.
The risks and challenges posed to the successful and timely development of offshore wind include:
• Moratorium on offshore wind leasing and development by the current federal administration and resulting COD uncertainty;
• Cost of transmission upgrades needed to enable development of fully deliverable north coast offshore floating wind projects;
• Uncertainty regarding costs of mitigating yet-to-be-identified environmental impacts of offshore wind, and how these costs will affect PPA pricing; • Coordination with central procurement conducted by the Department of Water Resources for long-lead time resources;
47 • Anticipated technology risk and high PPA price for floating offshore wind as a newly commercialized technology;
m. Transmission Planning
Transmission Upgrades for Contracted Resources
Of the contracted resources in RCEA’s Preferred Conforming Portfolio not yet online, only Drifter BESS will require transmission upgrades. Also included in this section are the contracted geothermal resources since they are interconnecting outside of CAISO and thus will require import capability rights for RA. The remaining contracted resources in the portfolio will be interconnected to the distribution system via PG&E’s Wholesale Distribution Access Tariff (“WDAT”), so will not require transmission upgrades.
Drifter BESS (COD 2033): This project’s interconnection is subject to extensive Reliability Network Upgrades (“RNU”) behind the in the Southern California Edison Transmission Access Charge region.
Fish Lake Geothermal (COD 2027): The project will connect to the Silver Peak substation in Nevada. It holds transmission rights on the Greenlink West transmission project to wheel energy to Eldorado. Until the Greenlink West transmission line is operational, the project will wheel energy to the CAISO side of the Silver Peak intertie point to deliver power to the CAISO controlled grid. The offtaking CCAs have secured import capability rights for the project.
Dogwood (COD 2027): The project entered the Imperial Irrigation District (IID) queue in 2023 and recently executed its interconnection agreement. Transmission service has been secured via a Transmission Service Agreement with IID to deliver power to the Imperial Valley intertie with CAISO. The offtaking CCAs are in process of securing import capability rights for the project.
48 (COD ): The project entered the IID interconnection queue in 2020. A restudy triggered by withdrawal of a higher queued project has delayed the interconnection agreement to the third quarter of . A transmission service request to deliver energy to the The offtaking CCAs are in process of
securing import capability rights for the project.
Humboldt-Specific Transmission Issues
Limited distribution and transmission capacity is a key issue for RCEA’s service area. , which has an average annual peak load of 100 MW, existing generation capacity of over 200 MW, and approximately 70 MW of transmission capacity connecting to the rest of the statewide grid.
RCEA’s power generation portfolio and load were significantly impacted by the first PSPS events of 2019 and continue to be impacted to a lesser extent since then. Following the first set of events, RCEA and local agencies engaged PG&E to assess the capability of RCEA’s service territory to island from the grid during future PSPS events are caused by high fire risk outside the Humboldt County grid. In summer 2020, PG&E was able to successfully test powering the majority of the local grid using the black start and grid forming capabilities of its HBGS facility, and there were significantly reduced PSPS impacts to RCEA’s generation and load during the subsequent fire seasons. While the local power plants are able to electrify the majority of the county’s distribution grid, outlying mountain areas do remain without power when there is a regional PSPS event.
PG&E’s islanding of the local grid powered by HBGS had an unforeseen consequence for RCEA’s RPS portfolio in that generators of 1 MW or greater were forced to disconnect during the islanding events. PG&E has claimed this is necessary to operate the local grid in a stable manner while it is islanded. When this happens, RCEA experiences significant financial harm due to disconnection of its local RPS resources resulting in procurement of replacement energy and substitution RA, plus foregone RECs. PG&E has instigated this practice during other types of transmission outages in addition to PSPS events and although the frequency and duration of generator disconnections has reduced in the last several years, RCEA remains concerned about future financial impacts to RCEA and local generators. RCEA engaged PG&E on this issue to 49 explore whether alternative practices can be implemented that avoid or reduce renewable energy generation disconnections during HBGS islanding, or that mitigate financial impact to RCEA and local plant owners, but no substantive actions to this effect have yet been accomplished as a result of the effort.
With the prospect of PSPS events occurring seasonally for a decade or more while utility infrastructure is modernized and wildfire risk is mitigated, RCEA in partnership with SERC is seeking opportunities and funding to support development of additional islandable, renewably powered microgrids following the RCAM model to serve outlying communities who are still at risk of PSPS shutoff, with temporary distributed generation using nonrenewable fuels as their only currently available option.
One such effort is the Tribal Energy Resiliency and Sovereignty (“TERAS”) project, for which RCEA is assisting three local Tribes with a DOE grant in partnership with the Schatz Energy Research Center. The project seeks to leverage multiple funding sources for nested microgrids to serve outlying areas that experience some of the highest frequency and longest duration outages on the entire PG&E distribution system. These microgrids will be comprised of various generating technologies including solar PV, and hydropower, and battery energy storage, and will be owned and operated by the Tribes. See Section IV(c) for additional information on the TERAS project. Planned Resource Transmission Needs
Two resource types that RCEA has included as planned new resources in its Preferred Conforming Portfolio are offshore wind and in-state geothermal. Viable locations for development of these resources are limited and many intersect with transmission constrained areas of the grid. There are potential synergies in the build-out of transmission for both resources, as one of the transmission corridors being evaluated for Humboldt offshore wind traverses the area of Northern California where development of new geothermal capacity is being evaluated.
RCEA’s Preferred Conforming Portfolio includes a total of 519 MW of planned new resources to be built at the locations identified in RCEA’s Resources Data Template. Table 13 provides a list 50 of these resources, their identified locations, and RCEA’s preferred alternate locations if the Commission’s modeling finds that the selected locations are not feasible.
Table 13: RCEA Preferred Conforming Portfolio Planned New Resource Locations Resource Name
Contracted
Capacity
(MW)
Selected Location Preferred Alternative
Location
Redwood Coast Offshore Wind 9.9 Humboldt WEA Morro Bay WEA Morro Bay Offshore Wind 6.48 Morro Bay WEA Humboldt WEA CADEMO Offshore Wind 3 Morro Bay WEA None
Local Small Hydro 10 Humboldt County Trinity County
Generic Geothermal Projects 120 Nevada Idaho
Enhanced Geothermal 26.2 NP-15 None
Generic Wind 1 29.2 NP-15 SP-15
Generic Wind 2 42.9 SP-15 NP-15
Generic BESS 74.3 NP-15 SP-15
Generic Solar 1 100 SP-15 NP-15
Generic Solar 2 100 NP-15 SP-15
IV. Action Plan
a. Proposed Procurement Activities and Potential Barriers Below are the activities RCEA intends to undertake across resource types to implement its Preferred Conforming Portfolio. Per the CPUC’s guidance, barriers are integrated into the discussion of each new resource identified. A summary of barriers that are cross-cutting or otherwise do not relate directly to any specific resource type are described in Section IV(a)(xii). i. Resources to meet IRP mandated procurement requirements, including D.21- 06-035 and D.23-02-040:
1,000 MW of firm zero-emitting resource requirements
RCEA has contracted for up to 4.55 MW of new geothermal capacity through its share of two executed contracts from CC Power. RCEA expects these two contracts to provide 3.96 MW of MTR NQC (based on September ELCCs) which satisfies its 3-3.5 MW obligation for firm zero-emitting resources. The 13 MW Fish Lake geothermal project is expected to be online by July 51 2027, of which RCEA’s share is 0.47 MW. As represented in the RDT, the project has high viability scores with subsurface characterization complete, a signed GIA, and construction commencing later this year. The CC Power members have also secured the MIC at the project’s delivery point sufficient to claim a long-term reservation, as discussed in Section III(j).
The Ormat geothermal portfolio currently consists of two IDD projects. Importantly, although CC Power is hopeful the Ormat contract will provide 125 MW of capacity for MTR, only 64 MW is guaranteed. The CC Power members are currently in process of securing MIC.
CC Power is closely tracking development progress of the Fish Lake and Ormat projects, and is pursuing additional geothermal contracts to procure on its members’ behalf, in the event Ormat does not meet the 125 MW maximum capacity in the PPA. 1,000 MW of long-duration storage resource requirements As discussed in Section III(i), RCEA contracted the Tumbleweed and Goal Line LDS projects through CC Power, which were both expected to be online by 2026 in time for the Commission’s LLT resource deadline. The Tumbleweed project did reach commercial operation in Q2 of 2026. However, the developer of the Goal Line project elected not to proceed with the project and the agreement with CC Power was terminated. CC Power has since contracted with Hydrostor for a portion of the capacity for its Willow Rock long-duation compressed air energy storage project as an MTR compliance replacement for Goal Line, with RCEA as a participant.
High-cost relative to the uncertain market value of LDS is a barrier to procuring these resources.
Revenue estimates of energy arbitrage and ancillary services for these assets are highly speculative in future years.
2,500 MW of zero-emissions generation, generation paired with storage, or demand response resource requirements
For its Diablo Canyon Nuclear Power Plant replacement capacity, RCEA procured solar plus storage from the co-loctaed Sandrini solar and BESS facilities, which came online in 2024 and 2025, respectively. RCEA procured short-term bridge capacity from another solar plus storage 52 project to span the gap between the June 1, 2025 MTR deadline and the expected Sandrini BESS COD.
All other procurement requirements
RCEA’s general incremental capacity obligation pursuant to the IRP Procurement Orders is 7 MW by August 1, 2023, an additional 20 MW by June 1, 2024 and an additional 5 MW by June 1, 2025.
To procure this capacity, RCEA issued a solicitation in Q3 2021, as described above, and has since executed two contracts. The Fairhaven Energy Storage project is a 17.25 MW standalone short-duration battery to be built in RCEA's service area at the site and to utilize the interconnection capacity of the former DG Fairhaven biomass plant. It is expected the facility will be operational in Q4 2023 and provide 16.6 MW of MTR capacity in time for the 2024 tranche. The second project is Foster Clean Power A, a 3 MW solar plus 1.25 MW storage facility to be built in RCEA's service area. It is expected the project will be operational as energy-only in summer 2023, after which the project owner will pursue full capacity deliverability status ("FCDS") through CAISO's Distributed Generation Deliverability process. FCDS would be awarded in Q2 2024, in time to provide 1.3 MW of MTR capacity for the 2024 tranche.
Despite best efforts to procure for the first IRP Procurement Orders deadline, RCEA currently does not have any incremental capacity procured for August 1, 2023. Both Fairhaven and Foster were shortlisted with CODs prior to that deadline, and a third project was shortlisted with a COD prior to the 2024 deadline. During the negotiation process, all three project CODs slipped beyond their original anticipated dates, such that Fairhaven and Foster could no longer meet the 2023 compliance tranche deadline, and the third shortlisted project could no longer meet any of the IRP Procurement Orders deadlines. The COD slippage was due to the developers’ concerns around supply chain delays and uncertainty in availability of specific equipment that their original bids were designed around. Given the late stage at which RCEA was notified of the delays, procuring a new project in time to comply with the 2023 obligation was infeasible. RCEA continues to make good faith efforts to comply with the mandate to purchase capacity from another LSE with excess MTR capacity and confidence in its own 2023 position. 53 ii. Plans for resources that are currently non-candidate in CPUC’s IRPs not described above
Pursue development of local small hydropower. RCEA’s planning documents, dating back to the original RePower Humboldt Technical Study in 2012, have identified the potential for tens of MW of new, low-impact run-of-the-river hydropower that can be developed in or adjacent to RCEA’s service area. In 2020 RCEA hired an expert consultant to perform an updated assessment of regional small hydropower potential and develop a plan for RCEA to facilitate development of feasible sites. The consultant’s final report, including identification of project sites with greatest development potential, and characterization of the hydrologic profiles associated with several diversion points on the candidate creeks, was completed in December 2021 and will inform RCEA’s next steps in facilitating small hydropower development, possibly including a solicitation in the coming years.
While small hydro presents a promising renewable development opportunity, there are numerous barriers including: uncertainty regarding environmental compliance and permitting needed for development; seasonal variation in production; vulnerability to drought while ensuring sufficient in-stream flows; and community acceptance of the development on remote creek sites.
Pursue additional clean microgrid projects as a source of local renewable energy and to foster community resiliency. RCEA has collaborated with SERC and PG&E on development of RCAM, designed to increase renewable generation in RCEA’s portfolio while providing resilience for a subset of its customers and ancillary services on the local distribution grid. RCAM is the first front-of-meter, multi-customer, renewable energy microgrid and became operational at the Arcata-Eureka Airport in late 2021. The project, funded through a CEC grant and USDA loan, has demonstrated the resilience benefits of microgrids, though it has not proven to be one of the more economic resources in RCEA’s portfolio. Equipment failures during the initial operating phase and Inability to date to be awarded full capacity deliverability status needed to obtain resource adequacy benefits have been factors in making the project less economic than expected. By 2025, the major equipment performance issues were successfully mitigated, and in early 2026 RCEA was awarded full capacity deliverability status for RCEA, pending network 54 upgrades needed to be able to show resource adequacy for the resource. Despite the challenges, there remains an important value proposition for microgrids in RCEA’s service territory. RCEA has been assisting local Tribes in obtaining funding to develop an interconnected set of microgrids on Tribal lands. RCEA is a potential offtaker for a portion of the generation that these front of meter microgrid resources would produce. iii. Offshore wind
RCEA was an early leader in advocating and planning for offshore wind on California’s north coast, developing a partnership beginning in 2018 with a coalition of developers with intent to maximize community control over eventual development of offshore wind. With the current federal administration’s opposition to offshore wind development in federal waters, including the two BOEM lease areas off the coast of RCEA’s Humboldt County service area, RCEA has turned its attention to potential offshore wind development in state waters. RCEA has engaged both directly and through California Community Power with CIERCO Energy, developer of the CADEMO offshore wind project, proposed to be built in near-shore waters adjacent to the Vandenberg Space Force base in Santa Barbara County. RCEA has included a planned small off-take from this project in its 8 MMT conforming portfolio. RCEA remains interested in and supportive of eventual development of north coast offshore wind, engaging with policymakers on development of Humboldt County port facilities and north coast transmission upgrades necessary for successful development of gigawatt-scale offshore wind in this area. iv. Out-of-state wind
As described In Section III(k). RCEA does not plan to procure any OOS wind and thus does not have any action items planned for this resource type. RCEA may pursue this resource in the future, and notes that OOS wind delivery barriers may mirror those that exist for OOS geothermal.
v. Other renewable and/or zero carbon resources not described above Continue to procure local biomass power and investigate opportunities for alternative uses of biomass waste. RCEA’s biomass PPA for the Humboldt Redwood plant was extended to 2031 but has not yet been procured through the end of the IRP planning horizon. As California’s 55 leading producer of forest products, Humboldt County incidentally generates a large amount of mill waste that must be disposed of, with biomass power plants having historically offered an important means of such disposal, while simultaneously providing a source of renewable energy. In conjunction with extending the PPA to its current term, and in response to community concerns about air quality and GHG impacts from biomass power, RCEA and HSC executed an MOU that encourages the parties to work together to identify and pursue economically viable alternative uses for the biomass feedstock, in an effort to plan for the transition away from combustion-based use called for in RCEA’s Strategic Plan. RCEA and HSC’s have been holding an annual meet and confer per the terms of the MOU since May 2022. As part of this process, HSC keeps RCEA informed on its continuing efforts to assess opportunities to use biomass feedstock for production of alternative energy products. At this time, no viable alternative for the continuous stream of biomass feedstock in Humboldt has presented itself, so RCEA has included continued procurement of the Humboldt Redwood plant in its Preferred Conforming Portfolio. To date, RCEA’s Board at multiple decision points has elected to continue procuring biomass power and has not indicated a firm date by which to end such procurement.
Extended procurement will continue to be weighed against other power supply options over the next decade in light of any feedstock alternatives identified through the aforementioned MOU process. Action to extend the contract is not anticipated prior to 2030, but given the multi-year timeline for procuring new-build resources that could replace HSC in RCEA’s portfolio, RCEA recognizes the need to develop a plan sooner for either retaining or replacing HSC..
The challenges associated with biomass procurement from existing plants include community acceptance of the combustion-based technology, particulate emissions staying within compliant levels, and the possibility of decades-old plants becoming less reliable or less efficient with time.
Support development of new geothermal power in California. In pursuit of their respective long-lead resource development goals, RCEA and SCPA have executed an MOU to collaborate on enabling transformative renewable energy development along the Northern California coast, specifically within the Humboldt WEA and the Sonoma-Mendocino GeoZone. The CCAs 56 are in early stages of collaboration in various areas including: advocacy for upgrades to the shared grid interconnection transmission corridors to the Humboldt WEA and GeoZone; mitigation of policy barriers for renewable energy project development; and the sharing of experience and information on partnerships and agreements for the mutual benefit of the CCA’s regions. The anticipated actions contemplated by this MOU are: to share non-confidential information on best practices and local Tribal and community engagement related to working with private entities in public-private partnerships; to understand, collaborate and engage with regulatory authorities and transmission operators on relevant transmission-related issues; to explore grant or public funding opportunities that are consistent with the purpose of this MOU; to develop communication strategies for engaging local and state agencies and elected officials in order to advance the purpose of this MOU; and to timely communicate with the other Party about relevant developments that could affect or impact the purpose of this MOU. RCEA plans to engage in all these activities with SCPA over the coming years in anticipation of an individual or joint procurement effort in the latter part of this decade.
RCEA is a participant in California Community Power’s Geothermal Exploration, Offtake and Development Engagement (GEODE) initiative, through which CC Power has entered memoranda of agreement with multiple geothermal power developers seeking to build new geothermal projects in California. If successful, GEODE will pave the way for offtake agreements between these developers and CC Power’s members, including RCEA.
Barriers to development of geothermal include potentially high cost and available transmission capacity to accommodate resource scale and timing. Geothermal development is relatively new in the regions RCEA is targeting, and there may be delays in planned development schedules due to unforeseen challenges.
The Humboldt-specific transmission issues described in Section III(n) pose significant barriers and potentially negative economic impact to development of new resources within RCEA’s service area. In addition, uncertainty in projects’ ability to secure a deliverability status for new resources in Humboldt due to insufficient grid capacity is a concern. The lack of locally based energy project developers with capacity to build projects at the 5-MW level (the maximum project size allowed in RCEA’s FIT Phase I program), and the reluctance of larger outside 57 developers to pursue projects at this modest scale in remote Humboldt County due to added mobilization costs appear to be additional barriers to implementing FIT projects. vi. Other energy storage not described above
RCEA recently contracted for Flycatcher 1 and 2 Energy Storage, a pair of 3 MW battery projects (6 MW total) sited at a former biomass facility in RCEA’s service territory, which will take advantage of the unused interconnection capacity and deliverability allocation at the site.
Another former biomass facility in RCEA’s service area was also considered by a developer for conversion to battery energy storage; however, this project has not advanced to date.
The main barrier to developing these former industrial sites is competing interests for use of the properties. The growing need for development of housing, business and recreation sites has increased, making such previously developed sites of high value for alternate uses to power projects.
vii. Other demand response not described above
RCEA’s efforts to date to implement demand response and other dispatchable distributed resource programs have met with challenges. RCEA in the past offered a program modeled on PG&E’s Peak Day Pricing program to incentivize peak shifting and peak shaving on the peak days called by PG&E. RCEA later created a Demand Reduction Incentive (DRIP) program that allowed RCEA to set its own peak days based on its procurement needs. However, analysis showed that these programs did not produce meaningful procurement cost savings for RCEA relative to their costs on administration.
RCEA also partnered with a company to create a fleet of behind the meter customer-sited batteries that could be centrally dispatched while also offering resiliency benefits to RCEA’s participating customers. However, RCEA’s project partner was not able to sign up the minimum number of customers called for in the program contract, and the program was eventually terminated.
RCEA has been meeting a portion of its D.19-11-016 procurement obligation since 2021 through a demand response program managed by a third part aggregator. This demand response 58 aggregation is not specific to RCEA’s service area or customers and includes participants throughout CAISO. RCEA continues to explore alternative, economically viable means of capturing the demand response opportunity in its own service area. viii. Other energy efficiency not described above
RCEA implements and administers numerous energy efficiency programs, some funded directly by RCEA’s CCA program and others via CPUC rate-payer dollars. Energy efficiency falls under the larger umbrella of demand side management, and regardless of the funding source, RCEA’s general framework for demand side management is to first evaluate opportunities for energy efficiency to decrease load, then assess opportunities for renewable generation resources to provide energy for the remaining load.
RCEA’s CCA-funded energy efficiency programs are implemented by its in-house Demand Side Management department, the key offering being the Public Agency Solar Program. The Public Agency Solar Program provides the following services at local government facilities: electric load analysis, energy efficiency upgrade options, solar site assessments, project feasibility studies, identification of funding sources, and contracting assistance. RCEA also offers a building decarbonization rebate program for heat pump space heaters and heat pump water heaters, and helps local organizations access additional funding opportunities.
RCEA’s CPUC rate-payer funded energy efficiency programs are intended to complement the CCA-funded initiatives. These include services and rebates administered in its role as an Elect-to-Administer PA and a LGP contractor for PG&E. In its PA capacity, RCEA provides technical assistance and incentives to customers for installing energy saving or demand reducing measures that result in sufficient quantifiable energy savings at low enough cost to pass the applicable total resource cost test. In its LGP capacity, RCEA provides "non-resource" services (services not associated with a specific energy savings target) including assistance with benchmarking and Energy Star certification of buildings, workshops and training, services for hard-to-reach customers, and referral of customers to PG&E “resource” programs (programs that do have quantified energy or peak demand saving targets). 59 RCEA also has a pending application to form a RuralREN program, which will provide energy efficiency services to hard-to-reach and underserved customers across rural regions in California. The CPUC is set to issue a decision on the approval of the RuralREN by Q4 of 2023.
Barriers to maximizing energy efficiency in the region are exacerbated, if not caused, by Humboldt County’s rural and remote geography. Challenges include limited skilled workforce in the region, lack of equipment stocked locally, minimal implementation and enforcement of Title 24 and other energy code regulations by building developers and officials due to lack of training, and high cost of travel to remote homes and businesses. Humboldt County’s aged and diverse building stock also makes it challenging to widely replicate energy efficiency measures.
RCEA’s existing energy efficiency programs aim to address these barriers, and the proposed RuralREN would provide funding to develop the robust local resources necessary to maximize energy efficiency gains in RCEA’s service territory.
ix. Other distributed generation not described above
As described in Section III(b) above, RCEA has partnered with Swell Energy to develop a customer program for dispatchable BTM energy storage. This Community Grid program, authorized by RCEA's Board of Directors in May 2021, aims to provide multiple benefits of 1) RA value to RCEA’s portfolio, 2) critical energy resilience to host customers, 3) utility cost savings to host customers 4) GHG emissions reductions, and 5) improved grid operability. The program leverages Self-Generation Incentive Program (“SGIP”) incentives to improve economics. The program is to deliver a minimum of 300 kW to a maximum of 3 MW of battery storage to be installed by Swell, or through Swell achieving operational control of systems already installed by other developers. The capacity will be aggregated as a virtual power plant (“VPP”) to supply RA capacity or load modification. The batteries will also be dispatched to reduce peak time-of-use charges for customers, while reserving 20% of battery capacity at all times for customer use during power outages. In addition to the SGIP incentives, customers will receive an incentive payment from Swell for participating in the dispatchable VPP. Contract terms call for 100% of customers to be enrolled by February 2023 and initial delivery to begin by May 2023. 60 A barrier to successful deployment of BTM battery storage via RCEA’s Community Grid program is the potential inability to realize full capacity of the program due to limited customer participation and competition for SGIP funding. To participate in the program, customers must sign Swell’s grid services agreement, which authorizes operation of the battery in accordance with the dispatch plan in RCEA and Swell’s contract. This is a deterrent for some customers, either because they don’t understand what their battery would be used for or are concerned that signing the agreement will result in unavailability of backup power when they need it. In addition, SGIP funding could limit program enrollment, as the pot of available money becomes fully subscribed.
On the operational side, other barriers facing the program are the cost and complexity involved with registering the VPP as a proxy demand resource to supply RA, as well as the uncertainty of realizing load modification value via the state’s load forecast and RA allocation process. RCEA and Swell’s contract is structured as an RA agreement with the option to transition to load modification should the RA product become uneconomic. Both pathways pose risk to RCEA. In particular, the cost and complexity of the Load Impact Protocol requirement for DR RA resources is a major barrier to establishing a supply side DR. Also, the maximum cumulative capacity limitation on DR capacity that can count toward an LSE’s RA requirement poses a barrier to increased distributed resource deployment in general. Lastly, lack of transparency as to how demand modifiers submitted with an LSE’s load forecast are factored into its allocated RA obligation makes it difficult to accurately estimate the value of such demand side resources. x. Transportation electrification, including any investments that correspond to different levels than what is included in Integrated Energy Policy Report (IEPR) As noted in Section III(g) above, RCEA's Strategic Plan calls for transportation electrification through adoption of electric vehicles and deployment of public, workplace and residential electric vehicle charging infrastructure. Coupled with targeted reduction of vehicle miles traveled, this is expected to reduce GHG emissions from transportation by over 65% by 2030, with a trajectory to eliminate fossil fuels for transportation, and thus transportation-related emissions, by 2050.
61 Working with the CEC and other partners, RCEA has produced three transportation-focused regional readiness plans, and has made progress on implementation of these plans: a North Coast Plug-in Electric Vehicle Readiness Plan (2014) 15, a Northwest California Alternative Fuels Readiness Plan (2016) 16, and a Regional Hydrogen Infrastructure Plan (2017). 17 The North Coast Plug-in Electric Vehicle Readiness Plan led to engagement with regional municipalities in a coordinated effort to streamline processes for the permitting and inspection of residential, commercial, and public EVCS; development of streamlined EVCS installation processes and detailed regional siting assessments, and engagement with potential site hosts; and education and outreach to promote PEV adoption through profile raising campaigns and installation of trailblazing signage for existing EVCS.
The Northwest California Alternative Fuels Readiness Project, which covered Humboldt and four surrounding counties, was led by RCEA, and launched to develop an established and engaged network of public and private stakeholders throughout the Northwest California region that can foster the successful introduction of alternative fuel vehicles, wise and effective deployment of alternative fuels infrastructure, and the development of a robust market for alternative fuels.
The North Coast and Upstate Fuel Cell Electric Vehicle (“FCEV”) Readiness Plan laid the groundwork to prepare nine of California’s northernmost counties for the introduction of FCEVs by launching a multi-county public engagement campaign to boost awareness of FCEV technology amongst a variety of stakeholder groups (e.g., general public, planners, fleet managers, state agencies), identify fueling infrastructure needs and ideal sites through stakeholder collaboration, modeling, and analysis.
The Humboldt Transit Authority was recently awarded a $38.7 million grant (total project cost $65.2 million) from the California State Transportation Agency’s Transit and Intercity Rail 15 https://redwoodenergy.org/wp-content/uploads/2021/03/FINAL-North-Coast-EV-Readiness-Plan-1.pdf 16 https://redwoodenergy.org/wp-content/uploads/2017/08/ARV-13-012_Readiness-Plan-FINAL_2017-02-23- small.pdf
17 https://redwoodenergy.org/wp-content/uploads/2017/08/10_19_17.FINAL_FCEV_Infrastructure_Plan.pdf 62 Capital Program to purchase 11 hydrogen buses and construct a fueling facility for these vehicles. The station will also support hydrogen car fueling. It is anticipated that hydrogen for this project will initially be transported into the area from an industrial hydrogen producer, likely made from reforming of natural gas. A future transition to local production of this hydrogen via electrolysis could increase demand for locally generated renewable electricity for transportation.
Hurdles to electric vehicle adoption include limited vehicle inventory and a lack of affordable local options due to supply chain issues and Humboldt’s remote geographic location. Akin to the rest of the state, FCEV adoption in RCEA’s service area is limited due to the absence of retail hydrogen stations to provide fuel for these vehicles.
While RCEA owns and operates REVNet, it does not own and operate all the stations in its territory. For stations that are not incorporated into REVNet, station providers are often delayed in responding to mechanical charging station malfunctions due to Humboldt’s remote geographic location. Additionally, Humboldt County has an especially old building stock. For this reason, panel and wiring upgrades are often required to accommodate charging station infrastructure at residences and businesses. These upgrades are expensive which presents a further barrier to widespread transportation electrification.
Finally, the southern Humboldt grid constraint issues described in Section III(n) could be a barrier to achieving RCEA's transportation electrification actions identified in this plan. RCEA is still working to understand the extent of how the constraints on PG&E's grid will impact the planned additional load anticipated from adoption of EVs and installation of charging infrastructure.
xi. Building electrification, including any investments that correspond to different levels than what is included in Integrated Energy Policy Report (IEPR) As detailed in Section III(g), building electrification is a key pillar of RCEA's Strategic Plan which seeks to "reduce greenhouse gas emissions from fossil fuel use in buildings by 20% by 2030 and maintain a trajectory to reduce emission from natural gas by 90% by 2050." 63 Under its current PA funding, RCEA is operating an EHPIC promoting non-residential and residential heat pump installations for space and water heating. This program is funded through June 2023. RCEA also offers incentives for direct install of a broad range of energy efficiency and fuel substitution measures including refrigeration, lighting, and kitchen equipment. This program is funded through June 2023. RCEA also offers rebates for residential heat pump installations and other energy efficient equipment.
Beginning in 2023 pending funding, RCEA will implement a TECH Quick Start grant focused on identifying and addressing barriers to electrification faced by users of unregulated fuels. These unregulated fuels make up an especially large fraction of fuel use in the rural, forested area served by RCEA, where fuelwood is widely available and propane is distributed by numerous retailers, while natural gas infrastructure is limited to communities in the central, more densely populated part of the county.
RCEA’s proposed RuralREN is also a funding source that will lead to building electrification investments above and beyond what is included in the IEPR; details regarding the RuralREN building electrification program offerings as well as the programs mentioned above can be found in Section III(g).
A substantial barrier to building electrification in RCEA’s service area, like transportation, is the southern Humboldt grid constraints described in Section III(g). These constraints are hampering the addition of new electrical load and transmission capacity must be expanded to accommodate successful building electrification. Costs of electrical panel upgrades in older buildings and replacement of gas appliances prior to end of life are consumer disincentives to building electrification that are especially acute in RCEA’s economically disadvantaged service area. Other barriers to building electrification mirror those described in Section IV(d)(viii). xii. Potential Centralized Procurement, pursuant to AB-1373 xiii. Other
Other Actions
64 Unlike most other CCAs in California, RCEA existed as a community-based energy services agency for many years prior to taking on its role as a CCA. Consequently, RCEA’s current version of its Strategic Plan, last updated in 2019 with extensive community engagement and input, describes many other energy functions the agency plays or intends to play in its Humboldt County service area, some of which complement or contribute secondary benefits to RCEA’s role as a load-serving entity. Among many others included in RCEA’s Strategic Plan, some key strategies include:
• Support renewable energy permitting, climate action planning, and countywide strategic energy planning. Humboldt County’s general plan recognizes RCEA as the County’s regional energy authority. In this role, RCEA is working with the County and its other member agencies to develop a multijurisdictional climate action plan that relies heavily on RCEA’s delivery of emissions-free energy to the community, The climate action plan is still in development and about to undergo the environmental review process. RCEA is also advocating for creation of designated renewable energy production zones by the County planning department to facilitate permitting of future energy projects that can contribute to RCEA’s power portfolio. • Support upgrade of the electricity transmission and distribution system. This activity is critical to ensure north coast offshore wind can be developed at a scale that not only contributes to RCEA’s own power portfolio but also increases regional grid reliability by enabling export of offshore wind power beyond the currently transmission-constrained Humboldt Local Reliability Area. Data available from PG&E also show that transmission and distribution within Humboldt County are highly constrained in multiple locations.
Resolving these constraints is critical to enabling interconnection of new renewable generation resources as well as being able to serve expanding load and support electrification and fuel switching.
• Reduce reliance on unspecified system power. Through the development of new renewable energy resources, energy storage capacity, and customer-sited distributed resources as outlined in this plan and the above actions, RCEA plans to phase out its reliance on unspecified system power, which makes up the majority of the GHG 65 emissions in its Preferred Conforming Portfolio. RCEA also aspires to reduce reliance on RA from combustion gas and other fossil resources, but this has not yet been officially adopted in its Strategic Plan.
Through its broader role as an energy authority in Humboldt County and beyond its status as simply a CCA or LSE, RCEA is empowered to advocate for and facilitate actions that ensure a reliable, locally sourced, decarbonized, and affordable energy portfolio is available to its electric customers.
Other Barriers
In addition to the topic-specific barriers integrated into Sections V(a)(i) through V(a)(xi), RCEA also considers the following potential barriers in its integrated resource planning:
Regulatory and legislative barriers
• Assignment of unexpected and unplanned resources (for example, through CAM, RMR, CPM);
• Legislative and regulatory changes that reduce the value or cost recovery of existing contracts (e.g., reductions of a project’s RA value within RCEA’s portfolio under the RA restructuring to Slice of Day).
• Shifts in procurement responsibility to the Central Procurement Entity, and potential shortfalls or other future changes to the CPE construct; • Anticipated change in law and associated regulatory risk have resulted in challenging contract negotiations for recent RA procurement by RCEA; • The timing of CPUC decisions about voluntary allocations of PCIA resources to RCEA, which could occur too late to allow timely portfolio optimization and compliance; and • National policy that restricts or penalizes trade with international suppliers (for example, the Department of Commerce’s ongoing “Initiative of Circumvention Inquiry on the Antidumping Duty and Countervailing Duty Orders”). • Ongoing CPUC microgrid proceedings (R.19-09-009) that may affect cost recovery through tariffs and market participation of microgrids including RCEA’s Redwood Coast Airport Microgrid;
66 Market barriers
• Construction timelines, especially considering current supply chain delays and issues.
Supply chain challenges have already led to delayed COD for multiple projects offered to or under contract to RCEA;
• Commodity and shipping cost increases, especially considering the recent reversal in solar module cost curves and potential industry shifts of these risks from developers to LSEs;
• Federal import tariff issues that affect industry-wide equipment costs; • The risk of CAISO curtailments of solar and wind resources that exceed current forecasts; and
• The risk of long-term resource procurement without any certainty of cost recovery; • Depending on preferred ownership models that emerge, Tribes and other candidates for new local decarbonization and reliability development projects may prefer BTM rather than front-of-meter systems, limiting RCEA’s role in bringing some of these resources online to technical assistance.
b. Disadvantaged Communities (DACs)
RCEA has several current and planned activities to increase equity throughout its region, several already described in previous sections of the narrative:
• Stakeholder engagement to inform RCEA’s Strategic Plan Update • Racial Justice Plan Implementation
• Supplier Diversity Program Update
• LGP program to deliver energy efficiency services to underserved and hard-to-reach customers
• RuralREN program deployment to bring energy efficiency services to rural underserved and hard-to-reach customers across the state
According to CalEnviroScreen 4.0, no Humboldt County census tracts fall within the state’s top 25% of impacted census tracts, or census tracts with the highest pollution burden. That said, 67 there are other important indicators of equity such as: income, unemployment, geographic proximity to services such as comprehensive medical care, living on land under tribal ownership, race, and more. Customers within RCEA’s service territory fall into categories, which often intersect and result in compounding levels of inequity.
In a rural context, equity in community engagement means including the voices of those who are far-removed from where decisions are made. As described in Section 3(b)(ii), RCEA engaged in extensive stakeholder outreach to inform the 2019 update of its Strategic Plan. RCEA traveled to remote regions of eastern and southern Humboldt County to receive community input on RCEA’s goals related to power procurement, transportation electrification, demand side management, and more. In response to community feedback received through these workshops and written comment, RCEA’s Board adopted a policy of transitioning to a 100% clean and renewable power portfolio by 2025. Apart from RA resources, RCEA intends to develop or contract exclusively with renewable and GHG-free generation resources, as well as energy storage resources. RCEA’s Preferred Conforming Portfolio does not include energy contracts for gas generators, including those located within or adjacent to DACs.
That said, as described in Section III(d)(ii), community concerns have been raised about air quality and GHG impacts from biomass power. In response to this concern, RCEA and the owners of the HSC biomass plant executed an MOU that calls for annual reporting on fuel use and sources, emissions, and information regarding HSC’s consideration of other potential feedstock uses that could result in reduced air quality impacts. RCEA communicates closely with the North Coast Unified Air Quality Management District to stay informed on air quality compliance status of the HSC plant.
In terms of evaluation criteria for power solicitations, RCEA considers project location and community benefits when evaluating responses to power solicitations in an effort to contract for projects that benefit racially diverse communities and to avoid projects that are detrimental to those communities. This is one key aspect of the power procurement section of RCEA’s Racial Justice Plan. Other procurement-related strategies include:
68 1. Incorporating energy justice best practices and affordability into renewable development and power purchase solicitations and resource planning.
2. Continue to implement its own Supplier Diversity program, in line with General Order 156, to promote participation of Diverse Business Enterprises in the power industry, including encouraging qualified energy suppliers to register themselves in the CPUC’s Supplier Clearinghouse.
3. For energy projects in which RCEA takes an active role in inception, development, ownership and/or operation, work with private partners to utilize collaborative and inclusive engagement with local communities throughout the development process, rather than a “decide-announce-defend” approach.
4. Seek partnerships with expert consultants on racially diverse community engagement, especially for large-scale projects such as offshore wind.
Since the inception of its CCA program, RCEA has provided program materials in both Spanish and English.
RCEA plans to improve and expand upon the outreach efforts described above to conduct targeted community outreach for future procurement, programs, and all agency activities. c. LSEs’ Tribal Customers
RCEA's service area is home to several California Tribes, namely the Big Lagoon Rancheria, Blue Lake Rancheria Tribe, Hoopa Valley Tribe, Karuk Tribe, Pulikla Tribe of Yurok People, Bear River Band of Rohnerville Rancheria, Cher-Ae Heights Indian Community of the Trinidad Rancheria, Wiyot Tribe and the Yurok Tribe. Because of this, many of the programs RCEA implements in the community serve Tribal members and Tribally-owned businesses and entities. The Racial Justice Plan goals related to Tribes are to strive to include Tribal representation, including Board representation, expand work with local Tribes on program development, customer outreach, and policy setting, and expand efforts to identify opportunities to collaborate with local Tribes as partners on sustainable energy initiatives. The Yurok Tribe and the Blue Lake Rancheria are now member entities of RCEA, with voting seats on RCEA’s Board of Directors. AB 117, which 69 made community choice aggregation possible in California, only allows cities and counties to form CCAs. In keeping with this, the Tribal Board members do not vote specifically on CCA business but do vote on all other RCEA governance matters, including budgets and policy direction.
RCEA has made progress this year in implementation of a $3,000,000 award to begin design, solicitation, and contracting to construct resilient energy systems consisting of solar panels and batteries at fire stations that serve high-fire risk areas. This effort is in partnership with the Yurok Tribe Fire Department, Karuk Tribe Department of Natural Resources, Hoopa Fire Department, and 13 other non-tribal rural fire stations. Additionally, in 2024 RCEA staff assisted the Yurok and Hoopa Valley tribal housing authorities with micro-grid feasibility studies for planned elder housing facilities. RCEA staff secured $20,000 to conduct the studies which included solar plus battery system alternatives and projected financial benefits.
In addition, RCEA is partnering with four Tribal Nations (Blue Lake Rancheria, Karuk, Hoopa, and Yurok) and Schatz Energy Research Center to apply for federal funding for the Tribal Energy Resilience and Sovereignty (TERAS) project. The TERAS project aims to increase reliability and resiliency for the Tribal Nations by developing microgrids. The project will serve vulnerable and historically under-resourced populations, in a fireprone region, while simultaneously pushing microgrid innovation and development. Lastly, RCEA is continuing collaboration with both Blue Lake Rancheria and the Wiyot tribe to apply for Department of Energy Home Electrification and Appliance Rebate (HEAR) funding.
d. Procurement Products
Product Description of Product
Fixed Price Power Purchase Agreements Direct agreements with energy facilities that include bundled attributes such as energy,
Renewable Energy Certificates (RECs) and
Resource Adequacy (RA) capacity
Fixed Price Inter-Scheduling Coordinator
transactions
Financial hedges for cost to serve load in the
CAISO energy market
Renewable Energy Certificates Market based procurement of RECs to meet RPS procurement requirements and Board-adopted
environmental goals
70 Resource Adequacy Capacity Attributes Market based procurement of RA to meet mandated procurement requirements and ensure
system reliability
Carbon Free Attributes Market based procurement of Carbon free energy to meet Board-adopted procurement
requirements and environmental goals
e. Commission Direction of Actions
Like other CCAs, RCEA encourages the Commission to adopt durable rules and processes to bring greater stability to the regulatory framework within which RCEA and other LSEs must plan and operate. Frequent rule changes disrupt RCEA’s ability to execute long-term planning activities and actions based on those activities while minimizing customer costs. Such regulatory changes can also result in duplicative procurement, stranded assets, disproportionately high costs and administrative burdens, which must be either absorbed by LSEs or passed onto customers via rate increases. For example, the Commission is currently considering a programmatic approach to the IRP through the Reliable and Clean Power Procurement Program and recently implemented a Slice of Day reform of the RA Program.
Each of these changes on their own represent significant regulatory uncertainty, which leads to market uncertainty. These changes together represent a complex, wholesale change to the regulatory landscape, which LSEs cannot reasonably account for in planning and procurement.
The Commission should be cognizant that the scope of these reforms may have broad, and somewhat unpredictable, impacts to the market. These market changes will likely alter planned procurement over the long term and may reduce the accuracy of LSE’s IRP plans.
RCEA also requests that the Commission issue guidance that states energy-only resources which are contractually obligated and on-track to obtain full or partial capacity deliverability status qualify for IRP procurement mandates at the time of commercial operation. Given that award of deliverability status can lag behind the generator interconnection process, there could be operational incremental capacity that is not accounted for in monitoring procurement pursuant to these mandates.
To further improve the efficacy of IRP-related procurement, RCEA supports an approach that is technologically neutral, and values resources based on their cost, emissions, and capacity 71 impacts, while allowing LSEs to simultaneously prioritize other customer benefits such as economic development and resiliency if in a position to do so. Giving LSEs the autonomy to select the resource mix to meet their share of statewide reliability and environmental objectives in tandem with their own constituents’ objectives, fosters more innovation (as evidenced through RCEA’s floating offshore wind initiative) and creates productive competition between developers and proposed technologies.
V. Lessons Learned
RCEA’s lessons learned and suggested changes to the IRP process for consideration by the Commission that would facilitate the ability of the Commission and LSEs to achieve state policy goals are detailed below.
• It is challenging to keep abreast of IRP requirements and instructions as they are modified and updated in the months leading up to the submission deadline, as this information is dispersed across the 2026 IRP guidance documentation, IRP ruling and slide decks, question and answer documents, and emails issued subsequently by the Energy Division. It would be helpful if the Commission and Energy Division staff were to issue comprehensive guidance at one time, and only to make changes when absolutely necessary. If changes to IRP guidance are needed, RCEA suggests consolidating those in successive versions of a single comprehensive and authoritative document for each required filing document, showing redline changes from the prior version. • The CEC’s IEPR load forecast has increasingly diverged from RCEA’s own load forecast over time. RCEA’s forecast is based on recent historic load data, which has been declining or flat year over year, while the IEPR forecast shows steady increase in load.
RCEA has engaged with CEC and Commission staff in the past year to highlight this discrepancy and ask for procedural change in load forecasting tied to the IRP. CEC staff have acknowledged the need to improve forecasting protocols. Inaccurate, oversized load forecasts when used to determine allocations in IRP-driven procurement orders from the Commission place an unfair burden on RCEA.
72 • A central database where the CPUC stores procurement data provided by LSEs and uses it to auto-populate templates would provide efficiency by ensuring consistent information is used in the various regulatory filings required, and sparing LSE staff from having to re-compile the same data in different formats for each filing. The IRS’s use of centrally stored taxpayer data to auto-populate tax returns or the Department of Education’s system for completing income fields in the FAFSA student financial aid form using IRS taxpayer data are models to consider emulating. • Like many CCAs, RCEA is a small organization with lean staffing, in which staff responsible for resource planning are the very same staff tasked with procurement and contract management contemplated in the plans. The CPUC’s IRP model came into being in an era when most load was served by a few large IOUs with the staffing and resources to conduct extensive analysis in developing their plans – plans that would each contribute hundreds or thousands of MWs of potential new procurement to the state-level resource planning. For smaller LSEs like RCEA, the effort entailed in developing CPUC IRPs may be out of proportion to the benefit the many resulting small-scale IRPs contribute to state-level resource planning. RCEA encourages the Commission to reconsider alternative IRP requirements that reduce administrative burden for smaller LSEs such as it has made available in the past. • Emissions accounting for biomass and geothermal resources in the CSP calculator doesn’t align with state emissions accounting methodologies. The model assumes zero GHG emissions from all renewables. In the case of biomass, this ignores the non-biogenic emissions tracked by the CARB and included in RCEA’s reporting to The Climate Registry for the specific plants RCEA procures from in keeping with state protocols for biomass emissions reporting. RCEA encourages the Commission to quantify incidental GHG emissions, such as those from ancillary use of fossil fuels in biomass facilities in the CSP calculator consistently with how they are accounted for by CARB. 73 Glossary of Terms
Alternative Portfolio: LSEs are permitted to submit “Alternative Portfolios” developed from scenarios using different assumptions from those used in the Preferred System Plan with updates. Any deviations from the “Conforming Portfolio” must be explained and justified.
Approve (Plan): the CPUC’s obligation to approve an LSE’s integrated resource plan derives from Public Utilities Code Section 454.52(b)(2) and the procurement planning process described in Public Utilities Code Section 454.5, in addition to the CPUC obligation to ensure safe and reliable service at just and reasonable rates under Public Utilities Code Section 451.
Balancing Authority Area (CAISO): the collection of generation, transmission, and loads within the metered boundaries of the Balancing Authority. The Balancing Authority maintains load-resource balance within this area.
Baseline resources: Those resources assumed to be fixed as a capacity expansion model input, as opposed to Candidate resources, which are selected by the model and are incremental to the Baseline.
Baseline resources are existing (already online) or owned or contracted to come online within the planning horizon. Existing resources with announced retirements are excluded from the Baseline for the applicable years. Being “contracted” refers to a resource holding signed contract/s with an LSE/s for much of its energy and capacity, as applicable, for a significant portion of its useful life. The contracts refer to those approved by the CPUC and/or the LSE’s governing board, as applicable. These criteria indicate the resource is relatively certain to come online. Baseline resources that are not online at the time of modeling may have a failure rate applied to their nameplate capacity to allow for the risk of them failing to come online.
Candidate resource: those resources, such as renewables, energy storage, natural gas generation, and demand response, available for selection in IRP capacity expansion modeling, incremental to the Baseline resources.
Capacity Expansion Model: a capacity expansion model is a computer model that simulates generation and transmission investment to meet forecasted electric load over many years, usually with the objective of minimizing the total cost of owning and operating the electrical system. Capacity expansion models can also be configured to only allow solutions that meet specific requirements, such as providing a minimum amount of capacity to ensure the reliability of the system or maintaining greenhouse gas emissions below an established level.
74 Certify (a Community Choice Aggregator Plan): Public Utilities Code 454.52(b)(3) requires the CPUC to certify the integrated resource plans of CCAs. “Certify” requires a formal act of the Commission to determine that the CCA’s Plan complies with the requirements of the statute and the process established via Public Utilities Code 454.51(a). In addition, the Commission must review the CCA Plans to determine any potential impacts on public utility bundled customers under Public Utilities Code Sections 451 and 454, among others.
Clean System Power (CSP) methodology: the methodology used to estimate GHG and criteria pollutant emissions associated with an LSE’s Portfolio based on how the LSE will expect to rely on system power on an hourly basis.
Community Choice Aggregator: a governmental entity formed by a city or county to procure electricity for its residents, businesses, and municipal facilities.
Conforming Portfolio: the LSE portfolio that conforms to IRP Planning Standards, the 2045 LSE-specific GHG Emissions Benchmark, use of the LSE’s assigned load forecast, use of inputs and assumptions matching those used in developing the Reference System Portfolio, as well as other IRP requirements including the filing of a complete Narrative Template, a Resource Data Template and Clean System Power Calculator.
Effective Load Carrying Capacity: a percentage that expresses how well a resource is able avoid loss-of-load events (considering availability and use limitations). The percentage is relative to a reference resource, for example a resource that is always available with no use limitations. It is calculated via probabilistic reliability modeling, and yields a single percentage value for a given resource or grouping of resources.
Effective Megawatts (MW): perfect capacity equivalent MW, such as the MW calculated by applying an ELCC % multiplier to nameplate MW.
Electric Service Provider: an entity that offers electric service to a retail or end-use customer, but which does not fall within the definition of an electrical corporation under Public Utilities Code Section 218.
Filing Entity: an entity required by statute to file an integrated resource plan with CPUC.
Future: a set of assumptions about future conditions, such as load or gas prices. 75 GHG Benchmark (or LSE-specific 2045 GHG Benchmark): the mass-based GHG emission planning targets calculated by staff for each LSE based on the methodology established by the California Air Resources Board and required for use in LSE Portfolio development in IRP.
GHG Planning Price: the systemwide marginal GHG abatement cost associated with achieving a specific electric sector GHG planning target.
Integrated Resources Planning Standards (Planning Standards): the set of CPUC IRP rules, guidelines, formulas and metrics that LSEs must include in their LSE Plans.
Integrated Resource Planning (IRP) process: integrated resource planning process; the repeating cycle through which integrated resource plans are prepared, submitted, and reviewed by the CPUC Long term: more than 5 years unless otherwise specified.
Load Serving Entity: an electrical corporation, electric service provider, community choice aggregator, or electric cooperative.
Load Serving Entity (LSE) Plan: an LSE’s integrated resource plan; the full set of documents and information submitted by an LSE to the CPUC as part of the IRP process.
Load Serving Entity (LSE) Portfolio: a set of supply- and/or demand-side resources with certain attributes that together serve the LSE’s assigned load over the IRP planning horizon.
Loss of Load Expectation (LOLE): a metric that quantifies the expected frequency of loss-of-load events per year. Loss-of-load is any instance where available generating capacity is insufficient to serve electric demand. If one or more instances of loss-of-load occurring within the same day regardless of duration are counted as one loss-of-load event, then the LOLE metric can be compared to a reference point such as the industry probabilistic reliability standard of “one expected day in 10 years,” i.e. an LOLE of 0.1.
Maximum Import Capability: a California ISO metric that represents a quantity in MWs of imports determined by the CAISO to be simultaneously deliverable to the aggregate of load in the ISO’s Balancing Authority (BAA) Area and thus eligible for use in the Resource Adequacy process. The California ISO assess a MIC MW value for each intertie into the ISO’s BAA and allocated yearly to the LSEs. A LSE’s RA import showings are limited to its share of the MIC at each intertie.
Net Qualifying Capacity (NQC): Qualifying Capacity reduced, as applicable, based on: (1) testing and verification; (2) application of performance criteria; and (3) deliverability restrictions. The Net Qualifying 76 Capacity determination shall be made by the California ISO pursuant to the provisions of this California ISO Tariff and the applicable Business Practice Manual.
Non-modeled costs: embedded fixed costs in today’s energy system (e.g., existing distribution revenue requirement, existing transmission revenue requirement, and energy efficiency program cost).
Nonstandard LSE Plan: type of integrated resource plan that an LSE may be eligible to file if it serves load outside the CAISO balancing authority area.
Optimization: an exercise undertaken in the CPUC’s Integrated Resource Planning (IRP) process using a capacity expansion model to identify a least-cost portfolio of electricity resources for meeting specific policy constraints, such as GHG reduction or RPS targets, while maintaining reliability given a set of assumptions about the future. Optimization in IRP considers resources assumed to be online over the planning horizon (baseline resources), some of which the model may choose not to retain, and additional resources (candidate resources) that the model is able to select to meet future grid needs.
Planned resource: any resource included in an LSE portfolio, whether already online or not, that is yet to be procured. Relating this to capacity expansion modeling terms, planned resources can be baseline resources (needing contract renewal, or currently owned/contracted by another LSE), candidate resources, or possibly resources that were not considered by the modeling, e.g., due to the passage of time between the modeling taking place and LSEs developing their plans. Planned resources can be specific (e.g., with a CAISO ID) or generic, with only the type, size and some geographic information identified.
Qualifying capacity: the maximum amount of Resource Adequacy Benefits a generating facility could provide before an assessment of its net qualifying capacity.
Preferred Conforming Portfolio: the conforming portfolio preferred by an LSE as the most suitable to its own needs; submitted to CPUC for review as one element of the LSE’s overall IRP plan.
Preferred System Plan: the Commission’s integrated resource plan composed of both the aggregation of LSE portfolios (i.e., Preferred System Portfolio) and the set of actions necessary to implement that portfolio (i.e., Preferred System Action Plan).
Preferred System Portfolio: the combined portfolios of individual LSEs within the CAISO, aggregated, reviewed and possibly modified by Commission staff as a proposal to the Commission, and adopted by the Commission as most responsive to statutory requirements per Pub. Util. Code 454.51; part of the Preferred System Plan.
77 Short term: 1 to 3 years (unless otherwise specified).
Staff: CPUC Energy Division staff (unless otherwise specified).
Standard LSE Plan: type of integrated resource plan that an LSE is required to file if it serves load within the CAISO balancing authority area (unless the LSE demonstrates exemption from the IRP process).
Transmission Planning Process (TPP): process conducted by the California Independent System Operator (CAISO) to identify potential transmission system limitations and areas that need reinforcements over 10- year and 15-year horizons.