ERRA/PCIA Reform, Track 2: Who Gets Credit for a Decade-Old REC?

SCE and other parties filed a joint prehearing conference statement in the CPUC’s ERRA/PCIA reform docket, outlining positions for Track 2, which is narrowly focused on whether Renewable Energy Credits generated before January 1, 2019 should carry a ratemaking value.

The investor-owned utilities argue that pre-2019 banked RECs were fully valued under the former PCIA methodology and that assigning a new value now would violate statutory indifference and impose retroactive cost shifts on bundled customers. CalCCA, the Alliance for Retail Energy Markets, and the Direct Access Customer Coalition argue that customers who later departed bundled service may be entitled to credits when those RECs are used for current Renewables Portfolio Standard compliance.

Additionally:

• Cal Advocates proposes broadening the scoping issues to address differences between pre-2019 and post-2019 indifference methodologies, not just REC characteristics;
• CLECA explicitly takes no position on Track 2 issues at this time; and
• CalCCA notes the pre-2019 banked REC valuation question has been litigated eleven times in prior proceedings without settlement, making adjudicated resolution likely necessary.