18. Independent Evaluator

PG&E proposes language that would "clarify that an IE is not required for other non-supply-side RFOs, such as for natural gas physical and financial products and other non-electric products." (PG&E Opening Brief at 20-21.) PG&E argues that this is consistent with D.07-12-052. Pacific Environment opposes this proposal, arguing that it is not consistent with prior Commission decisions, is not clear, and arbitrarily limits the types of projects reviewed by IEs. (Pacific Environment, Opening Brief at 23-25.)

Pacific Environment in turn proposes that the Commission's Energy Division use an IE to evaluate utility hedging and risk management "to ensure that unnecessary expenses are not being incurred." (Pacific Environment, Opening Brief at 29-30.) In addition, Pacific Environment recommends that an IE review the loading order and overall need, and urges the Commission to give IE reports "significant weight." (Id. at 23-25.) SCE opposes Pacific Environment's proposals, arguing that the proposals to expand the role of the IE are inappropriate and inconsistent with § 454 and Commission decisions. (SCE Reply Brief at 35-37.)

We decline to make the changes to the role of IE suggested by both PG&E and Pacific Environment. PG&E's proposal is vague, and may in fact inappropriately narrow the role of IE previously established by this Commission, while Pacific Environment's proposal would unnecessarily expand the role of the IE. We leave in place our existing rules for use of an IE.