4. Standardized Planning Assumptions

Because PG&E and SDG&E assert that they are generally free to ignore the standardized planning assumptions, they largely do not take issue with those assumptions. SCE, on the other hand, would be bound by its approved procurement plan, and accordingly takes issue with a number of the standardized planning assumptions. In a number of areas, SCE seeks to use its own assumptions, which generally would provide SCE more procurement flexibility, particularly for conventional resources, than the standardized planning assumptions.

The use of standardized planning assumptions is necessary, if for no other reason than to ensure that the procurement plans of the utilities (and positions of other parties) are comparable. Here, however, because PG&E and SDG&E are largely disregarding the existence of the standardized planning assumptions, that purpose is frustrated. In the future, as we move more towards SCE's approach, it makes sense to have the Commission adopt standardized planning assumptions for the utilities in the LTPP proceeding. Parties may advocate, as SCE did in this proceeding, for variations from staff-developed or staff-proposed assumptions.

SCE's proposal, which SCE refers to as its "preferred analysis," requests variations from the standardized planning assumptions. In addition, other parties have proposed changes to specific standardized planning assumptions. SCE is authorized to generally use its preferred analysis methodology, but only for up to five years from the date of this decision, and with certain exceptions as described below.⁴ Beyond that date, SCE must use the standardized planning assumptions, except as otherwise noted.⁵ This ensures that SCE's longer-term procurement strategies are consistent with the broader Standardized Planning Assumptions, while allowing SCE the flexibility to procure resources at just and reasonable rates.

⁴ See "Combined Heat and Power."

⁵ See "Direct Access and Community Choice Aggregation."