Sarah Kozal is an associate in Stoel Rives’ Energy Development group.
Before joining Stoel Rives, Sarah was an associate with Western Energy & Water (2016-2018). While in law school, she interned at the California Independent System Operator (CAISO) and was a legal clerk and research assistant at several organizations and law firms in Southern California, including the Emmett Institute on Climate Change and the Environment. Sarah also served as a member of the Delegation of The Republic of Palau to the United Nations Framework Convention on Climate Change Conference of Parties in 2014 and 2015.
Prior to beginning her career as a lawyer, Sarah worked in museum education in Los Angeles, focusing on outreach to and programming for underserved student populations.
In a stakeholder call yesterday, the CAISO discussed the Revised Draft Final Proposal in the Generator Deliverability Assessment stakeholder initiative. During the call, the CAISO addressed outstanding stakeholder questions, including confirming key upcoming dates for project developers. Background on the Proposal The CAISO is proposing revisions to its deliverability assessment methodology in response to the … Continue Reading
On July 29, 2019, the Ninth Circuit Court of Appeals affirmed the lower court’s decision in Winding Creek Solar LLC v. Peterman et al., ruling that California’s feed-in tariff for small qualifying facilities (QFs), the Renewable Market Adjusting Tariff (ReMAT), violates the federal Public Utility Regulatory Policies Act (PURPA) (Ninth Circuit Case No. 17-17531). ReMAT … Continue Reading
The California Independent System Operator (CAISO) is accepting stakeholder comments until August 13, 2019 on its new Hybrid Resources Issue Paper, kicking off a stakeholder initiative expected to proceed until April 2020. Initial comments submitted now will help shape the direction of the initiative and potential market changes. Though not exclusively limited to renewables + storage … Continue Reading
On April 25, the California Public Utilities Commission (“CPUC”) adopted a decision (“Decision”) in its Integrated Resource Plan (“IRP”) proceeding, R.16-02-007. The Decision examined the first round of integrated resource plans filed by each of the load-serving entities subject to CPUC jurisdiction. The Decision approved the plans filed by 20 load-serving entities, found that another … Continue Reading
The CAISO recently issued Part 2 of its Resource Adequacy Enhancements Straw Proposal and stakeholders met with the CAISO this week to discuss the paper and get further clarifications on the initial skeletal structure provided. As part of the process, the CAISO reviewed the counting rules in other ISO/RTOs and found that most ISO/RTOs use … Continue Reading
The 2019-2020 California Legislative Session has reached its first deadline. February 22, 2019 marked the deadline by which bills could be introduced for the first half of the Legislative Session. Lawmakers will begin Spring Recess April 12 and reconvene April 22. The last day for bills to be passed out of the house of origin … Continue Reading
FERC approved new changes to the CAISO tariff on February 19, 2019, with a retroactive effective date of November 27, 2018, that will impact projects in the CAISO’s generator interconnection queue. These changes are the result of a several month stakeholder initiative to enhance the interconnection process and follow a history of reforms intended to … Continue Reading
The CAISO is proposing several changes to the Resource Adequacy framework that will be relevant to generators both within and outside of California. CAISO is in the initial stages of developing their policy changes and it is a good time to voice concerns or offer suggestions before the changes are solidified. We expect more than … Continue Reading
The California Public Utilities Commission (“Commission”) voted recently to approve $768 million in expenditures for electric vehicle infrastructure programs proposed by the state’s three investor-owned utilities (“IOUs”). The programs are part of a directive of SB 350 that requires utilities to undertake transportation electrification activities. Here is a brief overview of the approved programs: Approved … Continue Reading
The Federal Energy Regulatory Commission’s (“FERC”) long-awaited Order 845 (Reform of Generator Interconnection Procedures and Agreements) was issued on April 19 after over two years of consideration of the issues. Order 845 is the first grid-wide major reform of FERC’s Generator Interconnection Procedures and Agreements since Order 2003 was issued 15 years ago. Order 845 … Continue Reading
Stoel Rives’ Energy Team has been monitoring and providing summaries of key energy-related bills introduced by California legislators since the beginning of the 2017-2018 legislative session. Legislators have been busy moving bills through the legislative process since reconvening from the spring recess. Below is a summary and status of bills we have been following. An … Continue Reading
In February, FERC issued Order 841, Electric Storage Participation in Markets Operated by Regional Transmission Organizations and Independent System Operators (the “Order”), requiring RTOs and ISOs to establish new market participation rules for energy storage that recognize the physical and operational characteristics of these resources. While the Order set forth some minimal requirements that each … Continue Reading