III. Coordination with CCAR, Governor's Climate Action Team and California Energy Commission
In D.06-02-032, the Commission recognized the need to work closely with the CCAR and the Governor's Climate Action Team, which includes the California Energy Commission (CEC), in moving forward with implementing a load-based cap7 In particular, as discussed above, the Commission recognized that implementation of an emissions registration requirement for generation resources would require close coordination with the CCAR. In discussing the development of a baseline and emissions reductions (and associated cap) over time, the Commission also stated:
"...we recognize that the CCAR is essential to this effort. We note that CCAR participated in the workshops in this proceeding by describing the emissions data collection efforts already completed and those underway. CCAR has also offered to work closely with the LSEs on the further development of emissions data and with this Commission in exploring the implementation options associated with a load-based cap.[footnote omitted.] We appreciate CCAR's constructive participation in this proceeding. We will work closely with them, as well as the Governor's Climate Action Team, in our efforts to establish baselines and associated GHG emissions caps."8
More generally, in discussing the implementation steps associated with a GHG emissions cap, the Commission articulated its intent "to coordinate closely with CCAR during this process to ensure that the appropriate data collection, reporting and tracking protocols are developed in tandem with these implementation steps."9 Similarly, consistent with Energy Action Plan II, the Commission stated its intent to collaborate and coordinate with the Governor's Climate Action Team, as well as other state, regional or federal agencies that are exploring design options for cap-and-trade programs, throughout the implementation of D.06-02-032.10
Accordingly, as envisioned by D.06-02-032, we will work closely with the CCAR and Climate Action Team members, including the CEC. It is my understanding that these organizations do not intend to participate as parties to this rulemaking.
7 Executive Order S-3-05, issued by Governor Schwarzenegger on June 1, 2005, called for the California Environmental Protection Agency (CalEPA) to lead a multi-agency effort to conduct an analysis of the impacts of climate change on California and to develop strategies to achieve the targets and mitigation/adaptation plans for the state. This effort is now being referred to as the Climate Action Team. The Climate Action Team is currently comprised of representatives from the Governor's Office, CalEPA, California Public Utilities Commission, California Energy Commission, California Department of Transportation, Resources Agency, California Air Resources Board, California Integrated Waste Management Board and California Department of Food and Agriculture.
8 D.06-02-032, mimeo., p. 40.
9 Ibid., p. 53. See also Finding of Fact 24.
10 Ibid., pp. 3, 5, 10, 26, 46, 55 and Conclusion of Law 1.
