​Integrated Resource Planning – CPUC Adopts Citation Program

Earlier this year, the California Public Utilities Commission (“CPUC”) adopted a Reference System Portfolio in the 2019-20 cycle of their Integrated Resources Plan (“IRP”). The March 2020 decision requires Load Serving Entities (“LSE’s”) to file individual resource plans with certain data on how the LSE’s will achieve their allocated share of a system-wide “Reference System Plan”, which is comprised of 46 and 38 Million Metric Ton (CO2(e)) scenarios. The March Decision requires LSE’s to submit their plans using CPUC-generated modeling files by September 1, 2020.

At the August 7, 2020 CPUC Business Meeting, the CPUC determined how and when it will assess penalties and issue citations relating LSEs' individual IRP submissions. The final citation resolution is available here. Penalties will be assessed on a daily basis ($500 - $1000 / day). Specified violations include the failure to submit a standard plan, new resource data, or other information as may be required in future CPUC rulings.

Meanwhile, the CPUC is continuing to develop program rules to implement the procurement track decision from the 2017-18 IRP cycle which allocated a requirement to purchase 3,300 MW of system resource adequacy capacity by 2023. The CPUC is currently evaluating development milestones that LSEs must meet to avoid “back-stop” procurement by the Investor Owned Utilities.

Contact: Brian S. Biering and Andrew B. Brown