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Please see attached 
CLEAN COALITION COMMENTS ON THE IMPACT OF TRANSMISSION ACCESS
CHARGES ON IMPEDING DEVELOPMENT AND CONTRIBUTION OF DISTRIBUTED
RENEWABLE GENERATION IN ACHIEVING GREENHOUSE GAS REDUCTION GOALS

SUMMARY
Cost effective reduction of GHG emissions requires accurate
assessment of the cost of alternatives and selection of the lowest
total net cost option. Under current CAISO tariff language,
transmission access charges (TACs) are assessed against the gross
customer load of the state’s major investor owned utilities instead
of the portion of load served by transmission resources (i.e. as
measured at the transmission interface). This has the impact of
assessing the delivery cost of local distributed renewable
resources that serve loads without the use of the transmission
system comparably to generation delivery cost of utilizing the
transmission system. As a result, local renewable generation is not
credited with the full avoided cost value it can offer, and
development of lower net total cost local renewables is depressed.
Correction of this cost allocation would support accurate least
cost and best fit procurement of resources required to reduce GHG
emissions.