Comments on Process for Integrated Resources Planning

  • Jun 28, 2017
  • Comment Letters

Agency: California Public Utilities Commission

Subject: Comments of the Association of California Water Agencies on Staff Proposal on Process for Integrated Resources Planning

Letter excerpt:

A number of ACWA’s member agencies have invested in a broad array of distributed generation technologies, including both bulk and battery storage, behind-the-meter solar photovoltaic, and other behind-the-meter renewable generation such as in-conduit hydropower. Water agencies also have a long history of participation in demand response, and ACWA appreciates the Commission’s consideration of all of these resources under a single proceeding.

Given the unique relationship between pumped storage and water supply infrastructure, ACWA is particularly interested in the Commission’s treatment of bulk energy storage in the IRP. ACWA is a party to R. 15-03-011, Energy Storage Procurement and Framework, and encourages the Commission to include comments already submitted in that proceeding if the Commission chooses to proceed with opening a “new track or proceeding… to further explore any capital intensive, long-lead time resources (e.g. … large-scale pumped hydro)”. In addition, as the IRP process “highlights the cost impacts of action that address different state and local policies and goals”2 ACWA encourages the Commission to consider both the full lifecycle costs of each resource or technology, as well as the full range of benefits that each resource can provide.

Download ACWA’s comment letter

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