Comments on State Energy Storage Procurement Framework Feb 4, 2016 Comment Letters Agency: California Public Utilities Commission Subject: Opening Comments of the Association of California Water Agencies on the Assigned Commissioner and Assigned Administrative Law Judge’s Scoping Memo and Ruling Seeking Party Comments Letter excerpt: Since the adoption of D.13-10-040 and D.14-10-045, there have been a number of changes in the state’s renewable energy goals. In his January 5, 2015 inaugural address, Governor Jerry Brown increased the state’s target for renewable energy from 33 percent by 2020 to 50 percent by 2030. This new target was codified with the passage of SB 350, the Clean Energy and Pollution Reduction Act of 2015, on October 7, 2015. On April 29, 2015, Governor Brown issued Executive Order B-30-15, which established a new greenhouse gas emissions reduction target for the year 2030 and directed Air Resources Board staff to update the AB 32 Scoping Plan. The new renewable energy target is being incorporated into the Scoping Plan Update. These actions taken on the part of the Administration and Legislature indicate that large amounts of renewable energy will be coming online over the next 14 years. A number of changes will need to be made to the electricity infrastructure in order to accommodate this influx of renewable energy. One of these changes will be development of increased storage. In order to achieve the necessary storage, both large, transmission-scale and small, distribution-scale storage projects should be considered in updating the state’s Storage Framework. Large scale pumped storage is a proven technology that can potentially provide a cost-effective solution and support the incorporation of more renewable energy into the state’s electricity mix. As noted by the Commission in D.13-10-040, “we will also continue to track the development of pumped storage technologies over 50 MW in size, and may consider including them in the Storage Framework in the future.”3 In light of these policy developments that have taken place since D.13-10-040 was adopted, ACWA would like to encourage the Commission to consider now as the time to include pumped storage projects that are greater than 50 MW, as well as smaller-scale, distribution-level pumped storage projects, as eligible for consideration in meeting the energy storage targets established in Track 2 of this proceeding. Download ACWA’s comment letter
