This entry covers CLECA’s filings in CPUC Rulemaking R.22-11-013 responding to the July 31, 2026 Proposed Decision updating the Avoided Cost Calculator (ACC). The excerpts below are drawn from CLECA’s comments and reply comments on the Proposed Decision.
The revised calculation suppresses the value of dispatchable DERs
CLECA endorsed PG&E’s explanation that, because generation-capacity value is derived as a residual, elevated GHG values push it down and weaken the signal for reliability resources.
Since generation capacity value is calculated as a residual output of the Integrated Calculation, elevated GHG values directly suppress generation capacity avoided costs.
Programs designed to deliver load reductions from dispatchable DERs during constrained system conditions derive a significant share of their benefits from avoided generation capacity value. Reducing that value may make these resources appear less cost-effective even as the Commission continues … to plan for a future where these resources are expected to serve as important reliability tools.
The Base Interruptible Program is a clean, firm, dispatchable resource
CLECA identifies the Base Interruptible Program its members supply as exactly the kind of resource harmed by a capacity value stuck at the floor.
The Base Interruptible Program (BIP), which many CLECA members supply, is such resource. Indeed, BIP is clean and firm.
CLECA agrees with PG&E that the Commission should consider whether a methodology that “consistently prices generation capacity at or near the floor level appropriately reflects the reliability value that dispatchable DERs are expected to provide.”
The ACC should reflect the full IRP portfolio
CLECA argues the adopted solar-plus-storage hybrid marginal resource does not represent the IRP portfolio the state relies on for reliability.
The IRP does not build hybrids: solar-plus-storage is not a candidate resource in RESOLVE, and the IRP neither requires nor plans for the two to be developed together.
The consequence is a marginal resource that reflects two chosen technologies rather than the portfolio the ACC is meant to represent, and the continued exclusion of the resources the IRP relies upon for reliability, including demand response.
A reasonable cap on the GHG value, applied to inputs
CLECA urges the Commission to adopt a reasonable GHG cap and stresses that any cap or smoothing must be applied to the model inputs so results are not distorted.
CLECA concurs with both parties and urges the Commission to adopt a reasonable cap for GHG.
Whatever capping or smoothing is applied, it must be applied to the inputs of the model such that the results are not distorted, as has been argued by CLECA, SEIA, and PG&E.
Correcting the generation-capacity floor
CLECA presses for a narrow correction to the understated generation-capacity floor, which omits ad valorem taxes and insurance.
The Commission acknowledges that CLECA, joined by Southern California Edison (SCE) and Solar Energy Industries Association (SEIA), identified that this floor is understated because it omits ad valorem taxes and insurance.
This systematically and significantly understates capacity value and, in turn, undervalues reliability-providing DERs, including BIP, that depend on accurate capacity signals.
Correcting the floor would not affect IRP results
In reply, CLECA adopts SEIA’s and SCE’s point that fixing the floor is consistent with the IRP and would not disturb its modeling outputs.
SEIA identifies that this “is irrelevant. Such an update would not impact the IRP results, as it is a cost parameter for operating fossil plants that are not selected in the IRP.”
SCE summarizes the principle aptly: “consistency with the IRP means ensuring that ACC values reasonably reflect IRP findings, not that the ACC must replicate every modeling output.”
Read the filings
The excerpts above are drawn from CLECA’s filings in this proceeding. Read the complete documents: