DISCUSSION OF MERIT FOR APPROVAL. Xxxxxx concurs with PG&E management that the Xxxxxx XX contract merits CPUC approval. In Arroyo’s opinion the contract offers high net value, low contract price, and high project viability. It would contribute to PG&E's efforts to meet its RPS Goals. Xxxxxx has scored the project as moderate with respect to portfolio fit. Arroyo’s qualified opinion, based solely on post-hoc document review without direct observation of negotiations, is that the negotiations for this project’s output were fair to ratepayers and fair to competing developers. PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV AT&T Department of Water Resources North America Power Partners Xxxxxxxx & Xxxx LLP Dept of General Services North Coast SolarResources Ameresco Xxxxxxxx & Xxxxxxx Northern California Power Association Xxxxxxxx & Poole Xxxxxx & Brand Occidental Energy Marketing, Inc. XXXX Xxxx Energy OnGrid Solar Xxxxxxxxx & Xxx, Inc. Economic Sciences Corporation Praxair Xxxxxx Xxxxx Associates Xxxxxxx Xxxxxxxxx & Xxxxxx LLP X. X. Xxxx & Associates Bloomberg Xxxxxx Farms RCS, Inc. Bloomberg New Energy Finance X. X. Xxxxxx & Assoc. Recurrent Energy Boston Properties GLJ Publications SCD Energy Solutions Xxxxx Xxxxxxxx XxXxxxxxxx, X.X. XxxXx Energy, Inc. SCE Brookfield Renewable Power Goodin, MacBride, Xxxxxx, Xxxxxxx & Xxxxxxx XXXX CA Bldg Industry Association Green Power Institute XXXXX CLECA Law Office Xxxxx & Xxxxxx San Francisco Public Utilities Commission CSC Energy Services Hitachi Seattle City Light California Cotton Ginners & Growers Assn In House Energy Sempra Utilities California Energy Commission International Power Technology Sierra Pacific Power Company California League of Food Processors Intestate Gas Services, Inc. Silicon Valley Power California Public Utilities Commission Xxxxxxxx Berkeley National Lab Silo Energy LLC Calpine Los Angeles Dept of Water & Power Southern California Edison Company Cardinal Xxxxx Xxxx, Xxxxxxx, Xxxxxxxx & Scripps LLP Spark Energy, X.X. Xxxxxx, Xxxxx XXX Lighting Consulting Sun Light & Power Center for Biological Diversity MBMC, Inc. Sunshine Design Xxxxx, Xxxx MRW & Associates Xxxxxxxxxx, Xxxxxx & Brennan City of Palo Alto Xxxxxx Xxxxxx Xxxxxxxx Xxxxxx Xxxxxxxxx & Associates City of Palo Alto Utilities XxXxxxxx & Associates Tecogen, Inc. City of San Xxxx Xxxxxx Irrigation District Tiger Natural Gas, Inc. City of Santa Xxxx Xxxxxxx Irrigation District TransCanada Clean Energy Fuels Xxxxxx Xxxxxxx Turlock Irrigation Distri...
DISCUSSION OF MERIT FOR APPROVAL. In Xxxxxx’x opinion, the amended and restated contract between PG&E and Shiloh Wind Project 2 merits CPUC approval: • The CPUC found the original PPA to be reasonable, including its pricing, which is unaltered in the amended contract. While Xxxxxx currently ranks the PPA’s contract price as high and net market value as likely low compared to recent competing proposals, the relevant peer group considered by the Commission when approving the original PPA would have included competing proposals submitted to PG&E’s 2006 and 2007 RPS solicitations, not perfect foresight of market conditions in 2017. • The insertion of provisions for PG&E to exercise a buyer curtailment option ' provides ratepayers with a material benefit with no change in contract price. This allows PG&E to avoid taking delivery of the project’s energy when CAISO market prices turn negative, when ratepayers would otherwise pay the facility for delivering a product that is worth less than zero. The CAISO is already experiencing a modest frequency of such negative- price episodes and could experience more as additional intermittent resources are built and come on line in California. Xxxxxx does not have an independent estimate of the value for incorporating the buyer curtailment option into the Shiloh Wind Project 2 PPA. PG&E performed a valuation of the new buyer curtailment option based on net market value (rather than Portfolio-Adjusted Value) as the metric. Using the utility’s current model inputs, PG&E’s net market value methodology attributes a value ' to the option, as the present value of ratepayer benefits through avoiding purchases of energy during periods of negative market pricing. This estimate does not count additional system benefits that the Portfolio-Adjusted Value methodology would ascribe to the curtailment option beyond the net market value of energy. ' ' • By taking on the role of scheduling coordinator from the seller, PG&E’s ratepayers will be exposed to a greater likelihood of paying CAISO imbalance costs and penalties. It is not yet evident how much costlier to ratepayers the incidence of imbalances for this facility will be under the revised CAISO tariff. Xxxxxx does not have a basis for estimating the incremental average cost to ratepayers of PG&E taking on the scheduling coordinator role. That being said, PG&E’s ratepayers already absorb these risks for hundreds of megawatts of projects under contract, and the number will continue to rise as new contracted projects com...
DISCUSSION OF MERIT FOR APPROVAL. In Xxxxxx’x opinion, the 83WI 8ME contract merits CPUC approval: • The contract price (after adjustment for time-of-delivery factors) ranks low when compared to all Offers received in PG&E’s 2012 RPS solicitation, and ranked low among the shortlisted proposals that PG&E considered for execution. • PG&E’s estimate of Portfolio-Adjusted Value ranks the contract as high compared to all 2012 Offers; it ranks moderate in PAV within the short list that PG&E considered for contract execution. Xxxxxx’x independent analysis ranks the contract as high in net value when compared to all 2012 Offers. • In Xxxxxx’x opinion, the proposed Midway Solar Farm I facility ranks as moderate in project viability. Its developers do not yet have experience developing, constructing, or owning, operating, and maintaining a single solar photovoltaic facility as large as 50 MW. However, European affiliates of GASNA have considerable experience bringing smaller solar PV projects into operation, the facility has obtained its interconnection agreement from IID and its conditional use permit from Imperial County, and does not face serious impediments to obtaining required network upgrades. Xxxxxx believes that Midway I should reasonably be able to meet its guaranteed commercial operation date. • The PPA ranks moderate to high in portfolio fit when compared to all 2012 Offers when using PG&E’s metric for adjusting PAV for timing of contribution to RPS compliance needs. • The project will be sited near a community afflicted with high unemployment, high poverty rates, and high emission levels. Overall, Xxxxxx’x opinion is that the 83WI 8ME contract merits CPUC approval based on superior pricing, moderate to high value, and moderate project viability. PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV 1st Light Energy Xxxxxxxx & Xxxxxxx OnGrid Solar AT&T Xxxxxx & Brand Pacific Gas and Electric Company Xxxxxxxx & Xxxx LLP Xxxxxxx Xxxxxxxxx & Xxxxxx LLP Praxair Xxxxxxxx & Xxxxx G. A. Xxxxxx & Assoc. Regulatory & Cogeneration Service, Inc. BART GenOn Energy Inc. SCD Energy Solutions Xxxxxxxxx & Xxx, Inc. GenOn Energy, Inc. SCE Xxxxxx Xxxxx Associates Goodin, MacBride, Xxxxxx, Xxxxxxx & Xxxxxxx SDG&E and SoCalGas Xxxxx Xxxxxxxx XxXxxxxxxx, P.C. Green Power Institute XXXXX CENERGY POWER Xxxxx & Xxxxxx San Francisco Public Utilities Commission California Cotton Ginners & Growers Assn In House Energy Seattle City Light California Energy Commission International Power Technology ...
DISCUSSION OF MERIT FOR APPROVAL. In Xxxxxx’x opinion, both the contract amendment to extend price relief under the existing contract and the new five-year agreement with Wheelabrator Shasta merit CPUC approval. • The CPUC found the project’s 2011 price relief amendment to be reasonable, including its pricing; the current amendment’s pricing is than the price of the 2011 amendment that applied in the last eleven months of its term. While Xxxxxx ranks the PPA’s contract price as high compared to recent competing proposals from projects delivering renewable energy, the more relevant peer group to which to compare this short-term amendment is other recent opportunities available to PG&E from biomass-fueled facilities that agree to deliver power in the short term from biofuel harvested from High Hazard Zones. The pricing of the new contract ranks low to moderate compared to that peer group; its value ranks moderate to high. • Similarly, the contract amendment will likely result in payments above the market price of renewable energy. This might amount to excess payments in the vicinity of by ratepayers above what they would pay for renewable energy at market prices, depending on market and performance outcomes. The $/MWh net market value of the Wheelabrator Shasta amendment deliveries will however be those of previous price extensions that PG&E granted to other QFs that are burning HHZ fuel and those of proposals received in PG&E’s BioRAM solicitation for delivering energy derived from HHZ fuel. The contract amendment is an immediate means of obtaining bioenergy from HHZ fuel at a value better than or comparable to competing alternatives. • While the price of the new five-year contract ranks high compared to competing proposals to deliver renewable energy, the more relevant peer group to which to compare this contract is other proposals from biomass-fueled facilities that offered to deliver power from biofuel harvested from High Hazard Zones. The price of the new agreement ranks low when compared to those proposals that still remained available to PG&E after the BioRAM RFO selections were completed. • The Portfolio-Adjusted Value of the new contract in levelized $/MWh ranks high compared to those of competing proposals for HHZ fuel-derived energy that were available to PG&E after the BioRAM solicitation. Xxxxxx independently ranked the new contract as moderate in net market value among those proposals. However, Xxxxxx agrees that contracting with Wheelabrator Shasta was the highest-valued alter...
