Contrary To The Renewable Justification For Sunrise, The Commission Now Clarifies That For GHG Reduction Purposes It Is Irrelevant Whether Or Not Sunrise Carries Renewables
The rehearing applicants, Center for Biological Diversity, Sierra Club, and Utility Consumers' Action Network all raise the GHG emission risks presented by Sunrise. The record shows that Sunrise could easily carry existing fossil-fired generation and facilitate the development of new fossil-fired resources outside the state. Existing transmission lines will connect Sunrise to out-of state resources, not only in the Southwestern U.S. but also to two existing gas fired plants totaling over 1,000 MW of capacity in Baja California in Mexico. Thus, the risk that Sunrise will increase, rather than decrease, GHG emissions is real and significant. This is one of the reasons my Alternate Decision proposed mechanisms to ensure that Sunrise carries Imperial Valley renewables. My proposal was, among other things, a mitigation measure to address GHG emission concerns by ensuring that Sunrise delivered on its GHG reduction promises.
The Order Denying Rehearing justifies the Commission's failure to mitigate GHG emissions in the manner I proposed by stating that GHG emissions under a 33% renewable regime will be the same, system wide, regardless of whether or not Sunrise carries renewables. So, in other words, under the GHG analysis supporting the Sunrise Decision, and clarified in the Order Denying Rehearing, the Commission refuses to impose feasible GHG mitigation measures through renewable procurement mechanisms that the Commission controls, arbitrarily states that such measures are infeasible, and instead states that it is irrelevant whether or not Sunrise carries renewables or fossil-fired power.
The Commission's conclusion is clearly at odds with the rest of the Sunrise Decision, which finds that the sole economic justification for approving Sunrise is that Sunrise will carry extensive amounts of Imperial Valley renewable power.
This conflicting analytical approach creates a fundamental and fatal inconsistency in the Sunrise Decision. The changes made to the Sunrise Decision in the Order Denying Rehearing do not eliminate the internal inconsistency.
Conclusion
There are other portions of the Order Denying Rehearing with which I disagree and which do not accurately characterize the Decision or the record. One example is the statement that the Sunrise Environmental Impact Report (EIR) "judged" the renewable condition contained in my Alternate Decision as "unworkable" and "determined it to be impracticable." This assertion - repeated in various forms throughout the Order Denying Rehearing - is not in the EIR. Moreover, the EIR was finalized prior to issuance of my Alternate Decision.
I thus dissent from the Order Denying Rehearing.
Dated July 9, 2009, at San Francisco, California.
/s/ DIAN M. GRUENEICH |
Dian M. Grueneich Commissioner |
