8. Clarification of Shareholder Obligation and Enforcement

DRA and TURN ask the Commission to take this opportunity to clarify the mechanism for enforcing the shareholder obligation. DRA and TURN believe PG&E should be allowed to use a combination of shareholder dollars and A&M funds to wind down the program and procure GHG reductions if the extension is denied. If, however, the extension is approved, DRA and TURN argue that the shareholder obligation should be calculated based on the deficit between the minimum guarantee and total GHG reductions supported through customer contributions collected through December 31, 2011.

We hold that consistent with D.06-12-032, the PG&E shareholder obligation is the difference between the minimum performance guarantee of 1.5 million short tons minus the total GHG reductions supported through customer collections through December 31, 2011.