15. Bilateral Contracts

PG&E proposes revisions to the existing criteria for bilateral contracts. PG&E recommends the removal of the Commission's existing "strong showing" standard for justification of bilateral contracts, along with other changes. PG&E argues that the existing standards are unclear. (PG&E Opening Brief at 16-19.)

DRA and Pacific Environment oppose PG&E's proposal to remove the "strong showing" standard, arguing that it is sound policy and that it is not unclear. (See, Pacific Environment Opening Brief at 18-20.) While there may be some ambiguity in the precise meaning of "strong showing," we decline to remove this requirement at this time. To the extent parties may wish to clarify the "strong showing" standard, they may do so in future LTPP proceedings.