The VAMO's Effect on RPS Procurement Plan Requirements
While the recent Decision on 2021 RPS Plans ("2021 RPS Plan Decision") removed the requirement for CCAs to discuss VAMO participation in their 2021 RPS Plans, the Decision does require VAMO participation to be discussed in 2022 RPS Plans. Additionally, the 2022 RPS Plan Decision approves SDG&E's Request for Information ("RFI") Plan. According to SDG&E's RFI timeline, SDG&E expects counter party responses to the RFI by February 1, 2022, and intends to notify LSEs of the RPS contracts available for assignment by March 1, 2022. Furthermore, a recent Joint IOU Motion to amend the RPS proceeding to accommodate the VAMO structure requests the Commission deal with the issue of REC classification of allocations through VAMO on an expedited schedule so that LSEs can make elections in May 2022. The Joint IOU Motion also requests the Commission clarify that IOUs will use a Commission-approved Voluntary Allocation Pro Forma Contract and executed contracts will not require review unless it material deviates from the pro forma contract.
2021 RPS Procurement Plans:
Decision ("D.") 22-01-004 ("2021 RPS Plan Decision"), removed the requirement to include information on their participation in the VAMO in their Final 2021 RPS Plans, due February 17, 2022.
CCAs encouraged to update their Final 2021 Plans if they have supporting information on whether they plan to participate in the VAMO process by taking allocations and/or purchasing RPS energy and RECs.
The 2021 RPS Plan Decision approved SDG&E's Request for Information ("RFI") Plan.
SDG&E RFI Plan - Submitted in SDG&E Draft 2021 RPS Plan
2022 RPS Procurement Plans:
The 2021 RPS Plan Decision requires the inclusion of PCIA related information in 2022 RPS Plans under Portfolio Optimization. Commission expects robust analysis and supporting information on the four portfolio optimization strategies on VAMO participation in the 2022 RPS Plans.
Decision ("D.") 21-05-030 ("VAMO Decision") requires IOUs to submit requests for allocation approval and market offer requests in their 2022 Final RPS Plans. CCAs required to request approval for allocations in 2022 RPS Plans.
Joint IOU Motion on VAMO Implementation and 2022 RPS Plans:
Expand the scope of the RPS proceeding to address whether Renewable Energy Credits ("RECs") retain their original Product Content Category ("PCC") classification only upon allocations under the VAMO process.
Provide guidance on the issue of the PCC classification of allocated RECs before Load Serving Entities ("LSEs") are required to decide whether to accept allocations in May 2022.
Clarify that Voluntary Allocation Pro Forma Contracts ("Allocation Contracts") will be reviewed in early 2022 via Tier 2 advice letter without a need to review executed contracts unless there is a material deviation from the approved pro forma, which contracts will be submitted under a Tier 1 Advice Letter for final review and approval.
