BAC’s Comments on RPS Integration Adder

BAC Comments on Integration Adder

The Bioenergy Association of California strongly supports the inclusion of a renewable integration adder with the recommended definitions and qualifications below.

  • An integration adder is important to account for the added generation capacity and ancillary services needed to firm and shape intermittent (variable) renewable resources;
  • The integration adder should be applied to intermittent renewables only since baseload and load-following renewables do not require firming and shaping;
  • The integration adder should focus on generation, not transmission and distribution;
  • If the Commission decides to adopt, or considers adopting, an integration adder for baseload renewables and fossil fuel generation, it should do so in a subsequent phase of this proceeding and only after the full implementation of SB 1122;
  • If the Commission considers adopting an integration adder for baseload renewables,then it should include the added values that bioenergy can provide, including flexibility,grid stability and voltage support (biomass and biogas); ramping and storage (biogas).