16. Contract Duration

SCE proposes to procure contracts of "5 years or less" in duration, rather than the currently-approved "less than 5 years" standard applicable to bundled procurment. (SCE Opening Brief at 10.) Under the "less than 5 years" standard, SCE is not preapproved to sign a standard five-year contract, but rather could only sign a four- year and 364-day contract. PG&E has a similar proposal, allowing it to contract further in advance. (PG&E Opening Brief at 31-33.)

On its face, SCE's proposal appears to be a simple, minor and common-sense change, and it was not opposed by any party. (Pacific Environment opposed PG&E's proposal.) At the same time, we are concerned that there are multiple previous decisions and existing regulations that contain provisions that specifically apply to contracts of "less than 5 years." On a policy level, SCE's proposal makes perfect sense, but on a practical level we are concerned that there may be unforeseen consequences of the change. The record in this proceeding is not adequate to evaluate those potential consequences. Accordingly, we decline to make either SCE's or PG&E's proposed changes now, but we invite parties to address this issue in more detail in future LTPP proceedings.