Why the ACC matters
The Avoided Cost Calculator (ACC) is the Commission-adopted model used to value distributed energy resources — energy efficiency, storage, and, most consequentially for CLECA members, demand response. Program cost-effectiveness, incentive levels, and tariff defenses all trace back to the ACC's outputs. If the model undervalues capacity, the Base Interruptible Program's cost-effectiveness is understated, its incentive payments compress, and its participation erodes. CLECA's ACC advocacy in R.22-11-013 and its predecessors spans seventy positions in the filing record, and it is among the most technically developed parts of CLECA's regulatory work.
The generation capacity floor and ceiling
CLECA's first recurring theme is that the ACC's Generation Capacity floor and ceiling are tied to assumptions that systematically suppress capacity values. The floor has been anchored to incumbent gas-plant operating costs — a technology-locked benchmark CLECA argues is inconsistent with the Integrated Resource Plan's own directives. In the 2026 working model, the post-2039 ceiling equals the floor, which effectively removes generation capacity from the optimization and invalidates the model on its face. CLECA's proposed fix is technology-neutral: derive the floor and ceiling from the highest-capacity-value resource the IRP actually optimizes, and correct the floor upward — from roughly $39 to roughly $64 per kilowatt-year — to include taxes and insurance that real resources carry.
The Integrated Calculation
The second theme is the Integrated Calculation methodology adopted in D.24-08-007. CLECA argued that the original two-by-two framework — two years of optimization, two resource types — mathematically excluded most resources the IRP identifies. The 2026 staff proposal moved in the opposite direction, deriving avoided generation capacity from a single solar-plus-battery hybrid with no optimization at all, back-calculating capacity after netting out IRP greenhouse-gas shadow prices. CLECA's comments press four corrections: build the calculation on a diverse, IRP-representative resource mix; raise the generation capacity floor; apply the GHG cap inside the integrated calculation rather than on top of it; and adopt a smoothing correction with a ten-year window so values do not whipsaw between updates.
The greenhouse gas avoided-cost cap
The third theme is the greenhouse-gas avoided-cost component. CLECA argues for capping GHG avoided costs at the Base Social Cost of Carbon rather than the High case, on the ground that values above the Base SCC have not been justified on the record and do not adequately protect ratepayers. CLECA has also documented structural problems in how the model computes avoided emissions: the SERVM production simulation treats new batteries as price-takers even when the analysis premise is thousands of megawatts of new storage that would re-equilibrate prices, overstating both energy and GHG avoided costs; and the hour-by-hour avoided-emissions method assumes gas is always the marginal resource in hours when it increasingly is not.
Process discipline
The fourth and most institutionally important theme is process. CLECA objected when the 2026 ACC working model was released only four days before formal comments were due, with no IRP-updated inputs. Its position is that the Commission must release ACC updates with current inputs and allow a genuine comment round before any methodological decision — because procedural deliberation is what creates a record on which the substantive arguments can land. That discipline, applied consistently since CLECA's first ACC comments in 2018, is why positions first articulated then still appear, in refined form, in the 2026 record.