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:

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.

In the update presentation today from PG&E, SDG&E, and SCE the results for the first 6 program period rounds of the ReMAT program for the solar projects was presented.

You can see that for SCE some sanity has occurred among the participants with the price at the $81/MWh level for the next acceptance period.  However you can see the insane actions by some participants in PG&E territory.  Financing a project of that small size at the $51/MWh level even if it had full capacity TOU payments would seem quite a challenge.

 

For baseload (geothermal etc.) and non peaking (wind and biogas) these programs are completely stalled with few participants as noted.

On May 29, 2014, SCE filed Advice 3045-E with the Commission which finalized changes in the RAM procedures and PPA documents.  There will be a web conference on June 5th but developers will have to be almost finished by that time on the large application documentation as the deadline for submission is still June 27th as expected.

SCE states a desire to purchase these allocations:

• solar 150-190MW
• wind 80-120MW
• geothermal, biomass 0-40MW

Later in the day both PG&E and SDG&E filed their advice letters for RAM 5, so the program is underway for June as expected.

There are other posting which have stated that the winning bids for the RAM 4 RFO were in the $0.073/KWh range, but I suspect that was at the high portion of the range.  This is of course before the TOU adder which is different for each of the IOUs and is much different with and without full capacity allocations.

Since the filing in December of 2012 by PG&E to try to terminate the third thru fifth year of their PV program this RFO for projects between 1-20MW has been in considerable limbo.  Let me refresh your memory on some aspects of this program.  This was the PG&E PV only program with a stated allocation of 250MW for the utility to build and 250 for IPP bids divided into 50MW for each over a 5 year period.  The SCE program was called the SPVP program with a bias for smaller ~1.5MW or lower rooftop projects.  These programs proceeded normally for the first two years, then the Utilities filed advice letters and requests to TERMINATE their programs and basically throw the remaining allocations into the normal RAM yearly offerings. Last year against their wishes(to my total surprise that they did not get what they wanted)  SCE was forced to hold the third round of the IPP portion, while being allowed to terminate their UOG portion and put that capacity into the RAM allocation.  That is why their RAM allocation was increased to the level seen today.

The new status is the rejection of the PG&E termination effort and their giving up for a third round of the IPP portion with an RFO in June.  There were earlier docs which were rejected but I believe this one from Feb 26 will probably be the accepted version, with some minor changes from the objection period.

Key takeaways:

• They desire to offer a PV only RFO for 58MW in June at the same timing for the RAM 5 RFO
• They desire to revise the PPA document to closely match that being used for the RAM 5 RFO.  There were different PPAs for projects 1-3MW and then up to 20MW in the first two years of the program and in the program design and CPUC approval at that time.
• Because of the initial program attributes projects from 1-3MW are allowed, one last time.  However going forward they will be excluded as is done in the RAM RFO.
• They and SCE are still trying to terminate the 4th and 5th year of the IPP program
• They will then place the remaining 4th and 5th years of both their UOG and IPP programs into a separate later RFO that is PV only but using the mechanics of the RAM RFO  This is a new 200MW opportunity. They specifically do not want this to be called a RAM 6 extension, but separate.

So in summary PG&E has been FORCED to have a third year PV program RFO like SCE was last year. It is the normal 50MW per year plus the 8MW coming from the terminated SilRay projects from the second year RFO.

So at present this change could produce a 58MW PV only PG&E RFO for this June and a psuedo RAM extension in PG&E territory for 200MW more over a new two year period.

The “2013 Preliminary Annual 33% RPS Compliance Report of Pacific Gas and Electric Company” was published today.  So let’s look at what they are saying now.

Using the data up to February 10, 2014 they had procured approximately 22.5% of their 2013 retail sales with actual 2013 deliveries from prior RPS procurements.  Of note is that 78% of this came from projects executed before June 1, 2010 and before the phenomenal drop in prices that have occurred in subsequent annual RFO and RAM solicitations.

Also they once again state no further need for Renewables until the 2020 time frame.

They state why in the 2013 RPS RFO they have sought incremental capacity with a preference for 2020 operation.

I would expect that the SCE filing will produce similar statements.

The coming Cluster 7 CAISO and SCE interconnection application deadlines for projects ~20MW and larger are approaching.  SCE has distribution circuits that support 20MW projects so I include their WDAT cluster in this discussion.  This window is from April 1st to April 30th this year.

So why could this be interesting?  Remember that starting with Cluster 5 in April 2012 the usual massive number of applications dropped off significantly as groups realized that obtaining a PPA and operating the projects before the ITC expiration deadline did not seem probable. Even now the Cluster 5 applications do not seem well set up for the RAM RFO in June, due to the timing of those interconnection completions.

Then why would you submit for Cluster 7 in a month from now?

What if you wanted to place a long term bet that the ITC issue would not be too bad, that the carrying costs of Cluster 5- Cluster 6 projects for 3-4 years would force most to drop them, and then you might be set up for a change in policy and need for PV at that time?  Also you would be able to resubmit projects that had earlier dropped out with known SIS and Facilities reports for possible reference to guess the cost when most in the prior queues had dropped out. The significant deposits from the Phase I and Phase II studies are not even starting until 2015, so you could have a bet with possible little carrying costs to see what happens.

Let us see what the leaders and new long term players think and how large this Cluster 7 group of submission becomes.

If you need help in developing projects for this application, surely give us a call to make that happen at Solar Land Partners, Inc.?

 

 

 

The first comments by all parties on whether the RAM program should be extended with a new authorization of capacity were filed on 1/30.  In these comments all three utilities (SCE, PG&E, and SDG&E) came out on the same side.  They claim the goals of the RAM program are already met, that they are meeting their RPS goals into 2017, and that the program should NOT be extended.

As usual SCE was the most opposed to any new program and had a new twist that they desired to use the RAM PPA contract with no negiotiation terms going forward in some future RFOs that might be needed later.

There was some language from PG&E about what they would propose if they were forced to accept a new program extension.

In other filings that have occurred PG&E had joined SCE in once again proposing that their IOU and IPP PV program be terminated and folded into the last RAM allocations. Again SCE is trying to terminate their SPVP program with the third year offering last year that they were forced to hold against their wishes.

In looking at the comments filed by the lobbying groups that usually have some clout in CPUC proceedings, it seemed to me that these were not strong enough to overcome the desires of the utilities to terminate the program with RAM 5 this coming June.

Comments and lobbying efforts should be made about this expected outcome, if your companies care about future RFOs for 20MW and lower size projects into next year.

This past week on 12/31/2013 ALJ DeAngelis issued  a ruling asking for comments on the possible expansion of the RAM program past the final RAM 5 in June of this year.  Additionally she asked for responses to questions regarding if the program should be changed, or terminated and other pertinent issues.

A nice table in that document can be used to make assumptions of the available capacity for each of the IOUs in the final RAM 5 round, if no further changes are allowed to spread this out.

SCE:    remaining allocation is   754.4(total allocation) – 483. 9MWs(thru RAM 4)  =  270.5 MWs

PG&E: remaining allocation is 420.9(total allocation) – 353.3 MWs(thru RAM 4)  =  67.6 MWs

SDG&E: remaining allocation is 154.7MWs(total allocation) – 117.5 MWs(thru RAM 4) = 37.2 MWs

You will notice that the total allocation is now 1,330MWs, up from the program authorization of 1GW.  That is due to SCE’s allocation being increased by the termination of their portion of the remaining SPVP program and their earlier RSC program being terminated for the RAM.

In the document, asking for comments, you can get some hint of what the CPUC is thinking.  For instance they mention the possible expansion of another 1GW program, but ask why the IOUs should have such a program with their RPS requirements being met into the 2017 time frame etc..

I would urge all utility solar companies in the CA market to actively lobby with regard to what will be ruled by the CPUC in the coming months to counteract the desires and influence of the IOUs in this proceeding.

Just now the advice letter from SDG&E was sent out for their winners and losers in RAM 4.  This advice letter is now in the approved category on the site.

For solar two Sun Edison projects were winners.  A 5MW project in San Diego County and a more interesting 10 MW project in tough San Bernardino County called “Vacaville Landfill”.

In the solar category this matched what they desired to acquire for this RAM round.  During this RFO they had a total of 97 bids from 37 companies for solar, wind, and biogas.  Silverado seemed to have submitted 21 offers for this cycle.

I will read and study this more over the next day or two to see if any new tidbits are different from the projects submitted for SCE and PG&E discussed in earlier blog posts.

What is important now is the large amount of strategy and work necessary in preparation for the final RAM 5 in the spring of 2014.  We at Solar Land Partners desire to help those working on this next round to secure a win at a price with a tolerable IRR.  This will be a tough one!!

According to the posting on 11/18, SCE had 25 projects that passed the tough application process for the solar portion of the first Re-MAT program.  This was a total of 42.9MW for the first period offering that will be at the 5MW level.

According to the winning rules, with this list then the 999KW and 1.5MW projects would be initially offered winning PPAs.  Since the third bid of 3.0MW goes over the limit of 5MW the auction stops there and the next 1.5MWs are not chosen to fill the bucket of 5MW.