California Energy Regulatory Weekly Update: January 6, 2020

This ruling formally initiates the “procurement track” as outlined in Decision (D.) 19- 04-040. The ruling generally describes the scope and content of the procurement track, and seeks comments from parties on its framing and structure. Identifying a mechanism to identify and procure near- and medium-term renewable integration and reliability resources is prioritized, followed by renewables to meet the 2030 needs identified in the Preferred System Plan adopted in D.19-04-040. Comments were due no later than July 15, 2019. On 7/25/19, the ALJ granted Cal-CCA’s request for extension of time to file reply comments to 8/12/19. On 9/12/19, the ALJ issued a proposed decision requiring electric system reliability procurement for 2021-2023. The decision recommends that the Water Board extend the OTC compliance deadlines for up to 3 years beyond the current deadlines. The decision also requires incremental procurement beyond the baseline resources assumed for the year 2022. On 9/20/19, the ALJ issued a ruling seeking comment on filing requirements for 2020 IRPs. Opening comments were due 10/14/19 and reply comments due 10/25/19. On 9/27/19 Enel X North America, Tesla, Sunrun, Center for Energy Efficiency and Renewable Technologies, CESA and Vote Solar filed a joint motion to establish a schedule and process for determining the capacity value of hybrid resources. On 10/21/19, the ALJ issued a revised proposed decision requiring electric system reliability procurement for 2021-2023 to address the potential for electricity system resource adequacy shortages beginning in 2021. The decision recommends extension of the OTC compliance deadlines for specified units, requires incremental procurement beyond the baseline resources assumed for the year 2022 and included in the Preferred System Plan and in addition to the OTC extensions, of system-level RA capacity of 4,000MW by all LSEs within CAISO’s balancing authority. Procurement shall be conducted on an all-source basis. The final decision D.19-11-016 was adopted by the Commission on 11/13/19. Prepared by California Regulatory Happenings for the Week of January 6, 2020 Buchalter Regulatory Happenings Weekly Report: Page 2 of 18 www.buchalter.com BN 39044787v2 On 11/6/19 the ALJ issued a ruling seeking comments on proposed reference system portfolio and related policy actions. Comments were due by 11/27/19 and reply comments were due by 12/13/19. On 12/5/19 the California Environmental Justice Alliance, Sierra Club, Defenders of Wildlife and the Public Advocates Office submitted an application for rehearing and clarification of D.19-02-007. The parties allege that the decision: 1) erroneously allows for procurement of new fossil fuel units and facilities; 2) commits legal error by allowing procurement of new fossil fuel capacity; 3) the allowance of new fossil fuel procurement is not supported by the findings; 4) substantial evidence does not support allowing new fossil fuel procurement; and 5) the joint parties will be prejudiced if this application for rehearing is not granted because they lack the ability to protest fossil fuel procurement in an evidentiary hearing. On 12/13/19 GenOn Holdings, Inc. filed an application for re-hearing of D.19-11- 016. GenOn requests rehearing on the limitation on OTC extensions to one year. On 1/3/20 the ALJ issued a ruling finalizing the baseline for purposes of procurement required by D.19-11-016. Streamlining Interconnection of Distributed Energy Resources and Improvements to Rule 21 (R17-07- 007) This rulemaking addresses streamlining interconnection of distributed energy resources and improvements to rule 21. A Proposed Decision was issued on February 22, 2019, adopting the Proposals from the March 15, 2018 workshop Group 1 Report. The Proposed Decision was approved at the Commission’s Meeting March 28, 2019. Status reports from working groups have been filed. THE CALIFORNIA ENERGY STORAGE ALLIANCE filed a motion to establish a subgroup and schedule a joint workshop with R18-12-006 to introduce proposal on mobile inverter technical requirements for Rule 21 interconnection. On 8/23/19, a Joint ALJ ruling establishing a subgroup and schedule to develop a proposal on mobile inverter technical requirements for Rule 21 was issued. A workshop was held on 12/17/19. On 11/27/19, the ALJ issued a ruling directing responses to attached questions and revising the schedule. Responses are due by 1/13/20 and reply comments are due by 1/27/20. Parties are permitted to include comments on the 6/14/19 working group three final report with their response. Prepared by California Regulatory Happenings for the Week of January 6, 2020 Buchalter Regulatory Happenings Weekly Report: Page 3 of 18 www.buchalter.com BN 39044787v2 Resource Adequacy, Consider Program Refinements and Establish Annual Local and Flexible Procurement Obligations for the 2019 and 2020 Compliance Years. (R17-09-020) On 10/24/19, CalCCA filed an application for rehearing of D.19-10-021, addressing RA import rules stating that the ruling does not affirm existing rules but rather creates new requirements that will effect a sea change in the way import RA is transacted and bid into the CAISO. In conjunction with the application for rehearing, CalCCA filed a motion for stay of the decision and motion to shorten the comment period. On 12/23/19 the Commission granted the motion for stay of D.19-10-021. On 10/30/19, CalCCA filed a petition for modification of D.19-06-026. CalCCA requests that the Commission grant Energy Division Staff authority to grant waivers of system and flexible RA requirements beginning with the 2020 compliance year. On 11/18/19 CAISO and Powerex each filed rehearing requests of D.19-12-021.