Comments on Petition to Modify Decision 17-01-006 Mar 31, 2017 Comment Letters Agency: California Utilities Commission Subject: Response of the Association of California Water Agencies to the Solar Energy Industries Association and the California Solar Energy Industries Association Petition to Modify Decision 17-01-006 Letter excerpt: In the Petition, SEIA and CALSEIA propose that schools be allowed one year to complete interconnection and that all other non-residential customers be allowed six months to complete interconnection once IOUs adopt new TOU rates. ACWA requests that the Commission consider allowing all public agencies one year to complete interconnection following adoption of new TOU rates due to the lengthy process that all public agencies must use in contracting and bidding for renewable energy projects. In D.17-01-006 the Commission notes that one of the reasons for offering an extended deadline for grandfathering to schools is “complicated public contracting and bidding requirements.”5 In an email dated January 18, 2017, the City of Pittsburg notes that “public contracting and bidding requirements affecting public agencies in general make it particularly difficult for public agencies to complete solar projects in an expedited manner. These requirements, and the associated delays, are not unique to schools, but rather affect all public agencies.”It takes much longer than a year for a public agency to design, permit, and build a new renewable energy project. Water agencies are concerned that they may not be able to complete construction and interconnection within six months of new TOU rate adoption, and that failure to obtain grandfathering under existing TOU rates will negatively affect the economics of their projects. Any unfavorable change in the economics of these solar energy projects could have a significant negative public impact since costs associated with these stranded assets are passed on to each agency’s ratepayer base. Therefore, ACWA requests that the extended deadline be offered to all public agencies, not just schools. Download ACWA’s comment letter
