Posted by: jbarnesca | February 27, 2011

SCE Implementation of RAM Program

On February 25th SCE filed their Advice Letter for the implementation of their new solar PV program by the CPUC  called the RAM(renewable auction mechanism) program.  Once again SCE leads the way in the implementation of the various CPUC programs for solar in California.

First of all note that the Utilities and CPUC have stated that all 20MW or under solar projects should submit for PPA agreements under the RAM, IPP program, or SB 32 programs, and NOT in future RPS RFOs.  So  in the future annual California RPS solicitations, they will be for projects larger than the somewhat optimized 20MW projects on the 69Kv lines of the utilities.

There are two related items that are somewhat in controversy from this proposal and the proposal of the CPUC in general.  The requirement to follow the new CAISO cluster agreement timing and the requirement to have operation within 18 months of “contract execution” are somewhat not aligned.  In the notice to the developer public SCE made particular mention of this fact as one to be aware of:

“One of the requirements SCE proposed to apply in the RAM Program is that a project must have an interconnection study in order to be eligible to submit an offer.  SCE’s proposal is to accept offers after the CAISO Cluster 4 Phase I interconnection studies have been completed.  The window to submit Cluster 4 interconnection applications is March 1, 2011 to March 31, 2011.”

Since the largest project allowed is 20MW for this program, and those projects are expected to have the lowest cost, this is a significant milestone to make.  For 5MW and smaller projects they would be connected onto the distribution grid of SCE and thus subject to their new GIP rules being submitted to FERC now; however, the 20 MW projects connected onto ~69Kv transmission lines under CAISO control must make the timeline stated.

This change in interconnection rule has also made for difficulties in meeting the 18 month construction date deadline of this RAM program.  Groups are forming to address this inconsistency in the program and IA timing, with Silverado being a leader with a nice formal “Request for Modification” letter to the CPUC on this subject.

In summary the 20MW projects need to be very careful in the timing of their completion dates with the upgrades caused by the cluster application process in their regions.  The particular requirements of the two programs(RAM and new CAISO IA cluster process) can cause a problem and make some 20MW project fail requirements of this new RAM program for 2011.

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