Common use of Additional Observations Clause in Contracts

Additional Observations. One subtle change to prior versions of the methodology was that in the 2012 RPS RFO PG&E agreed to explicitly calculate congestion cost for each Offer. The 2012 solicitation protocol displays the congestion cost multipliers for each load zone, where in prior RFOs an overall LMP multiplier was shown that incorporated the effect of both congestion and losses. Congestion charges estimated for each Offer variant were also displayed in the confidential summaries of valuations provided to PG&E’s Procurement Review Group. Decision ▇▇-▇▇-▇▇▇ ordered the three IOUs to treat congestion cost as a separate variable. As noted above, the 2012 solicitation protocol now omits resource diversity as a specific component of the RFO Goals criterion. It also omits environmental stewardship and local reliability, which were previously included explicitly as components (though environmental benefits to low-income, high-unemployment, or air pollution-suffering communities is included in the 2012 protocol’s statement of the RFO Goals criterion). This appears to reduce the justification the utility might invoke in selecting lower-valued Offers that enhance the technology or fuel diversity of the short list, or that would benefit grid stability in local areas with shortfalls of Local Resource Adequacy. It also appears to reduce the justification PG&E might use as the basis to reject higher-valued Offers that pose significantly higher environmental risks, such as unavoidable impacts to threatened or endangered species.