There is no doubt that California has mandated an aggressive Renewables Portfolio Standard (RPS), requiring utilities to procure 33% renewables by 2020. But the question on everyone's mind is, "How are we going to get there?" Typically, the large utility request for offer (RFO) process is the starting point. However, this year, the amount of uncertainty surrounding procurement of California renewables is at an all-time high, particularly given the recent amendments to California’s RPS resulting from Senate Bill 2X which require the California Public Utilities Commission (CPUC) and the California Energy Commission to interpret and implement many of the new law’s provisions.
On May 13, Southern California Edison (SCE) released its 2011 Renewables RFO to solicit offers from renewable power generators, making it the last of the Big Three California investor-owned utilities to do so in the last week. Pacific Gas and Electric Company (PG&E) and San Diego Gas & Electric Company(SDG&E) previously issued their 2011 Renewables RFOs on May 11 and May 12, respectively.
To put it bluntly, questions as simple as, “Will the electricity generated by my renewable project qualify for inclusion in the 2011 Renewables RFO, and if so, which procurement bucket will it qualify for?” will dominate discussions between the utilities and the generators. Candidly, the utilities won’t have answers to a number of these questions until the completion of a recently announced new renewables rulemaking by the CPUC, which by the CPUC’s own admission is expected to be a protracted process lasting at least 24 months. And even then, there are bound to be several unresolved issues which may leave renewable generators scratching their heads.
We recently issued an advisory summarizing the CPUC’s new renewables rulemaking. Those wishing to participate in the 2011 Renewables RFO should keep a close watch on the status of this rulemaking, and in the meantime, be sure to tread very carefully in your procurement discussions with the utilities.
The corresponding dates for (a) the pre-bidders conference and (b) deadlines for submission of proposals are listed below.
SCE Bidders Conference: May 26
Deadline for Proposals: June 27
PG&E Bidders Conference: May 19
Deadline for Proposals: June 15
SDG&E Bidders Conference: June 2 (San Diego), June 8 (El Centro)
Deadline for Proposals: July 11