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California Energy Comments.pdf

Comments-on-the-Proposed-Revisions-to-the-LMS-Rulemaking-04-20-22.pdf
Preview of California Energy Comments
🔗 Source: cal-cca.org
📊 Size: 237 KB
👤 Author: Buchalter Nemer
⬇️ Downloads: 92

Summary

The California Community Choice Association (CalCCA) submits comments on the proposed revisions to the Load Management Standards, arguing that the California Energy Commission does not have jurisdiction to mandate CCA compliance with the standards. CalCCA identifies several flaws in the proposed regulations, including the inability of CCAs to implement an hourly locational marginal cost-based rate, unsubstantiated claims that CCA costs to implement the LMS are negligible, and arbitrary exclusion of electric service providers and small publicly-owned utilities from the LMS. CalCCA asserts that the Commission's jurisdiction is limited to "utility service areas" and that CCAs are not "electric utilities" within the meaning of the Public Resources Code.

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Description

The California Community Choice Association (CalCCA) submits comments on the proposed revisions to the Load Management Standards, arguing that the California...

Technical Information

  • File Format: PDF
  • File Size: 237 KB
  • Pages: 12
  • Language: EN
  • Author: Buchalter Nemer
  • Total Downloads: 92
  • Last Updated: 1 month ago

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