[{"_1":2,"_87":-5,"_88":-5},"loaderData",{"_3":4,"_26":27},"root",{"_5":6,"_17":10,"_18":19,"_20":21,"_22":10,"_23":-5,"_24":-5,"_25":10},"user",{"_7":8,"_9":10,"_11":10,"_12":-5,"_13":-5,"_14":15,"_16":-5},"roles",[],"isAuthenticated",false,"isPremium","planName","subscriptionStatus","featureFlags",{},"insightsBudget","isDevelopmentHost","userPreferences",{},"recaptchaSiteKey","6LcvOJcUAAAAAHsB-gPGfGktcRlKpH7OTIU_dMTD","isImpersonating","impersonation","affiliateStatus","isFreedomPortal","routes/v2/article/layout",{"_28":29,"_30":31},"notFound",true,"relatedArticles",[32,75],{"_33":34,"_35":36,"_37":38,"_39":40,"_41":42,"_43":44,"_45":46,"_47":48,"_49":50,"_51":52,"_53":54,"_55":56,"_57":58,"_59":60,"_61":62,"_63":64,"_65":66,"_67":68,"_69":70,"_71":72,"_73":56,"_74":56},"mediaId",6195030,"mediaKeyId","3862927-176b7ee152d8733bbaec26914bf3ee78","parentId",3862927,"title","Company presses model PPA and ‘conforming-bid’ approach; parties debate red lines and bid comparability","audioSeconds",860,"startMs",8162000,"endMs",9022000,"viewUrl","/Search/View?dp=1&key=3862927-176b7ee152d8733bbaec26914bf3ee78&start=8162&end=9022","thumbnailUrl","https://assets.pipeline.soar.com/3862927-176b7ee152d8733bbaec26914bf3ee78/thumbnail_8162000.jpg","articleUrl","/articles/6195030/Colorado/Company-presses-model-PPA-and-conforming-bid-approach-parties-debate-red-lines-and-bid-comparability","mediaUrl","https://secure.pipeline.soar.com/6195030-f2b93d05b10cabb3ecb55ebd35929a4a/orig.mp4?Expires=1773540757&Signature=GVXtKnSZD1Wf6cte0yUVp4L319tlBWAErR7jfhd-69wQsRbpYTHbMTadFOAyx1UR-8woh~9Ojl7TvPAjPs8lz3DmjDfYT5NZ3k5mCysJV5XSgjkqUWqTSYmZHzXc5jydelO~KaLZDZFyrPJ6QxwmHTpQvQtNgMQenaQjXdZMsvhdPD4rCKHxoC44CZJBvj1wL2KMiRHSvfFEUPmVpUf~h973wRlv3kwxfowC43IN1YkANxsgMjxE7U7kjg-svR6aa29xxmS8dJHdAObEjG9-PNPK-VFKKDoqwJ-2Aavq54N9spq0-ojx2WN08rlrbyh6TVY~x~EFTbYJhqxubfaZDA__&Key-Pair-Id=KUT5TJCACFTXG","author","","date","2025-06-17T23:07:13Z","article","Public Service Company counsel told the Colorado Public Utilities Commission on June 17 the utility proposes a \"conforming-bid\" policy and a model power‑purchase agreement (PPA) so that bidders provide offers that are directly comparable without conditioning bids on extensive red-line edits. Counsel said the company will accept immaterial, clarifying edits after bid selection but will treat material changes differently to protect customers and reliability.

Why it matters: The Commission asked whether a standardized PPA and bid rules would reduce negotiation time and bidding uncertainty. Intervenors said bidders need to see proposed contract language in advance to evaluate risk; the company said pre‑litigation feedback was provided and warned that allowing red lines undermines comparability and can create delays and “short bidding.”

Key facts

- Company position: Counsel Bornhaughan argued the company will publish a model PPA and require bidders to provide firm, non‑conditional prices \"without markup or exceptions\" in their bids. He said bidders would not be allowed to condition offers on future red-line negotiations; after selection the company would allow immaterial clarifications and, in some cases, good‑faith negotiation on material matters that do not shift risk to customers.

- Intervenor pushback: Representatives for IPPs and trade groups told the Commission the company had not publicly posted all the specific red‑line changes (attachment JLB‑2) that the company said it would accept, and questioned whether those edits should have been confidential. Several intervenors also said a one‑size‑fits‑all model PPA could make projects harder to finance and could be unfair to sellers without visibility to final text.

- Security and other PPA items: Counsel discussed specific contract items that drew comment, including pre‑COD security levels (company’s draft raised the sample security to $200/kW from $125/kW in an earlier template) and provisions that would allow the company to acquire a failed project. Counsel said some changes reflected market practice or a desire to protect ratepayers; intervenors objected that changes were material and should be visible to bidders.

Context and supporting detail

Company counsel argued the conforming‑bid approach is meant to \"minimize bidder exceptions and to enhance bid comparability\" and to reduce time‑consuming red‑line negotiations after a shortlist is determined. Counsel also said the company had provided a matrix (attachment JLB‑2) responding to intervenor concerns and that it would abide by the same standard for all bidders if the Commission approves the conforming‑bid policy.

Intervenors pressed that bidders and their financiers need final or near‑final contract language before bidding so they can price and arrange financing. Counsel acknowledged a prior motion to keep some revised language confidential had been withdrawn and said the company would supply the record items in response to parties’ requests.

Ending

The exchange highlights a common tension in large utility solicitations between: (1) the regulator and utility desire for standardized, comparable bids that shorten procurement timelines and (2) developer and financier demands for contract flexibility or visibility so they can manage project‑specific commercial and financing risks. The Commission did not issue a final ruling on the conforming‑bid approach in the transcript excerpt.","mediaType","Video","parentTitle","24A-0442E, Public Service Company - 2024 JTS - 6.17.25 - HRA (5 of 9)","oneSentenceSummary","Public Service told the PUC it wants a conforming‑bid policy and model PPA to reduce red‑line bargaining and increase apples‑to‑apples comparability; intervenors pressed for changes and warned that some proposed model PPA edits should be visible to bidders before an RFP.","taxTitle","Public Utilities Commission, Governor's Boards and Commissions, Organizations, Executive, Colorado","taxId",28165,"location","Colorado","headline","shortSummary",{"_33":76,"_35":36,"_37":38,"_39":77,"_41":78,"_43":79,"_45":80,"_47":81,"_49":82,"_51":83,"_53":84,"_55":56,"_57":58,"_59":85,"_61":62,"_63":64,"_65":86,"_67":68,"_69":70,"_71":72,"_73":56,"_74":56},6195035,"Public Service describes two-step reliability checks, warns models can miss real-world stress",980,2015000,2995000,"/Search/View?dp=1&key=3862927-176b7ee152d8733bbaec26914bf3ee78&start=2015&end=2995","https://assets.pipeline.soar.com/3862927-176b7ee152d8733bbaec26914bf3ee78/thumbnail_2015000.jpg","/articles/6195035/Colorado/Public-Service-describes-two-step-reliability-checks-warns-models-can-miss-real-world-stress","https://secure.pipeline.soar.com/6195035-1d818b1759460ffc9e3b985019c5543c/orig.mp4?Expires=1773540757&Signature=WjXYO25yl9Qsz6HVdmNaLTpw2~FVJL0p79ULrymi6k8rIBVm4I8a98T6oWqvxT0uDls2P~eVjn-FUhyp8m0~hqenTsevuShP9tnc-E5sCRYomlfOVs6MUJfn46WJ3GQxi3A6djyEx9rOstj~~3Nn6vzGQhJUaHuAfDgpv3VvewPsibGpZ2HqOPvZrcrCankb~ai8-ZlCUjP0gdH1UTUIoEJMXvqfetIxATnXL9dS71GYE6pRAKiPlKDcQFN7wfnvmt8O~eM~QCRvG8nePfvySejyfCF~vq1gGEcZwTBunxv741I2m3-fM6qNb~owsanNsp4wwgry5A4gahit~6pdVw__&Key-Pair-Id=KUT5TJCACFTXG","Public Service Company witness Mr. Landrum told the Colorado Public Utilities Commission on June 17 that the utility will continue to use a two-step process to test whether proposed resource portfolios will actually keep the lights on under extreme weather. The company first uses a recap (E3) study to set a planning reserve margin consistent with a 0.1 loss-of-load-expectation (LOLE) and then runs those portfolios through an Encompass production-cost model. If Encompass — which the company says uses \"perfect foresight\" and certain simplifications — cannot operate the portfolio without unserved energy in real historical stress periods, the company will treat that as a verification failure and adjust the portfolio.

Why it matters: Utilities and regulators rely on planning models to pick resource mixes years in advance. The company said it needs a verification step because the production-cost tool can be optimistic: \"the model knows exactly what the entire year is going to look like, and it can make sure the batteries are fully charged before the wind stops blowing,\" Landrum said. If the Encompass run cannot solve a historically stressed period, the company will present versions of the portfolio that add capacity or swap resources until real‑world operability is credible.

Most important facts

- Company witness: Mr. Landrum (company witness for Public Service Company) described the two-step approach: a recap (E3) RA study to set a PRM for 0.1 LOLE, followed by an Encompass production-cost run and an additional \"reliability rubric\" verification that seeks 0 unserved energy in the Encompass run for historical extreme weather windows.

- Model differences (company's characterization): Landrum said Encompass uses simplifications and perfect foresight (for example: the model can optimally charge batteries in advance), which can make its results optimistic about actual operations.

- Company reporting commitments: Landrum said the company will present the Encompass results and the recap metrics together and can include relative NPVs of interim portfolios that fail the rubric so stakeholders can judge trade-offs.

- Near-term capacity concerns: Landrum told the Commission the company sees supply shortfalls in summer seasons near term (he cited shortfalls discussed in testimony: \"negative 643 megawatts in 2025 summer, negative 09/2026 summer, and negative 854 megawatts in 2027\" as reflected in his loads-and-resources discussion).

Context and supporting detail

Landrum described why the second test exists: the recap/RA studies that set reserve margins are not a one-to-one substitute for an hourly production-cost view of the system in stressed weather years. The company will report where a portfolio stands relative to the 0.1 LOLE recap metric and include Encompass energy-adequacy indicators such as unserved energy and ancillary service violations. \"So I will consider it more of a...a verification step, not...an additional criteria or a higher bar,\" Landrum said, adding that the step is intended to build confidence that model results are \"repeatable in real life.\"

The company also told commissioners that some portfolios that meet recap targets may still require a small amount of additional capacity or different resource mixes once verified by Encompass; Landrum said he does not expect wholesale overbuilding but said the company will \"call out\" any portfolio that looks \"ridiculous.\"

What commissioners asked

Commissioner Gilman pushed on whether the rubric effectively raises the planning standard from 0.1 LOLE to zero unserved energy and whether that gap could be costly. Landrum replied that the two analyses are distinct tools and that the rubric is designed to ensure Encompass results are not optimistic because of model simplifications.

Outlook / next steps

Landrum said the company will continue to report both the recap and Encompass results and provide stakeholders with information on portfolios that do not initially pass the rubric, including the possibility of showing relative NPVs. He also said the company can run alternative versions of portfolios (for example, excluding new large loads) after the Phase 2 decision to inform cost-allocation and interconnection discussions.

Ending

The exchange illustrated a core technical trade-off for regulators: allow a single planning standard, or require a second verification layer that may change portfolios—and potentially costs—after initial selection. The company framed the rubric as a verification of operability under historically stressed weather periods, not as a higher reliability target on its face.

","Company witness told the Colorado Public Utilities Commission that the utility will use a second \"reliability rubric\" after its recap/PRM analysis to check Encompass production-cost results and may adjust portfolios when the simpler model cannot replicate stressful weather periods in operational simulations.","actionData","errors"]

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Company presses model PPA and ‘conforming-bid’ approach; parties debate red lines and bid comparability

Public Service describes two-step reliability checks, warns models can miss real-world stress