Posted by: jbarnesca | October 23, 2014

Subtle Project Exclusion in PG&E IPP 3rd Year Program?

After fighting to terminate their IPP Solar PV program for almost two years, this third offering of 50MW per year is finally being announced as of October 21st. This third offering should have happened in 2013, but PG&E as well as SCE on their SPVP programs, fought hard to terminate them and put the capacity into the RAM 5 offering. Fortunately opposition forced them to keep these nice programs that might have capacity for some sub 20MW solar projects going forward.

This third offering will be for 50MW plus 8 MW from terminated prior winning projects. The 8 comes from 4 terminated 2MW projects initially by SilRay at a very low rate at the time of less than $0.07/Kwh.  In May of 2012 that would have seemed like an unbelievable low rate for small 2MW projects to produce a tolerable unlevered IRR for further financing and ownership groups.

Since 20MW projects are eligible for this program as well as 1MW projects we could expect only three winners again.  Two 20MWs and a downsized 18MW that was actually a 20MW interconnection application.  Thinking positively, maybe some 1.5MW and 2MWs might be allowed to win by PG&E to prevent too much complaining to the CPUC.

Strictly speaking one criterion for eligibility is clearly stated in their documents as:

IPP rule

It is well understood that for the full resource adequacy (full deliverability) TOU payment you must apply basically in the cluster process of CAISO each March for this determination. Also it is known that any application using the somewhat streamlined RULE 21 application process for smaller projects would have to separately apply for full deliverability in the March cluster.

However, the statement above, and in all docs approved for this program, would seem to imply that NO rule 21 small project application would be eligible for this program now or in the future?  If that is the interpretation, then projects of recent time that have been using RULE 21 and thought this was sufficient for programs of the sub 3MW size would be terribly surprised at this finding.


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