Green Power Institute Comments on the CEP

Storage Workshop at the PUCJuly 28, 2015

“Evaluation”

• The CEP includes the term, “evaluation,” which suggests that the CEP should be used for evaluation

• Options:1. Change the name to avoid ongoing confusion2. Preferred! Modify the CEP for the 2nd RFO so

that it is used for evaluation alongside the utility proprietary protocols, rather than only “benchmarking and reporting”

Commission Precedent is Contradictory

• The Commission stated in D.13-10-040 that the IOUs must “draw on” the CEP in their evaluation of bids (Appendix A, p. 8)

• A year later, the Commission stated in D.14-10-045 that the utilities must instead “draw on” the consultant reports in crafting their proprietary protocols and use the CEP only for benchmarking and reporting

• We recommend that the Commission return to the direction in D.13-10-040 and require the CEP to be part of the evaluation process for the 2nd storage RFO– Transparency is key and the current process is entirely opaque

More Detailed Comments

See “GREEN POWER INSTITUTE COMMENTS IN RESPONSE TO SCOPING MEMO AND RULING QUESTIONS,” in R.15-03-011, filed July 8, 2015

Thank you,Green Power Institute

• Gregg Morris, Director• Tam Hunt, consulting attorney