Aglet Consumer Alliance (Aglet)

Aglet makes 32 recommendations in its opening brief, many of which can be organized into the following categories: Regional and Service Need Determination; the Long-Term Plans in General; Procurement Issues; and Policy Issues. Of particular concern to Aglet was the need determinations for the IOUs and reforms to the procurement process.

To begin, Aglet recommends a reduction in the capacity procurement authorization for all three IOUs from the amounts they requested in their LTPPs. From Aglet's analysis of their respective needs, Aglet reduced PG&E's need from 2,300 MW to 662 MW, SCE's need from 1,380 MW to 0 MW,¹² and SDG&E's need from a range of 900 - 1,900 MW to 813 MW. Aglet supports its recommendations by suggesting that the IOUs demand response assumptions are too low and their contingency assumptions are too high. Aglet fears that all customers suffer when an IOU over procures capacity and energy that are not needed.

In regards to the Long-Term plans in general, Aglet suggests that there be a target of 50% UOG for all new contracts, renewable and non-renewable, with terms of ten years or greater because Aglet sees the percentage of UOG dropping, yet Aglet believes there are benefits to ratepayers from increased UOG.

Another key concern of Aglet is the procurement review group (PRG) established for each IOU's procurement process. Aglet is a strong proponent of the PRG, is an active participant in PRG meetings, and suggests some improvements, such as circulation of written materials ahead of the meeting and minutes after the meeting. Aglet also makes suggestions for the RFO process, contract and bid evaluation, and risk issues. While Aglet did opine on numerous other subjects and make many proposals for improvement, the topics discussed above give a brief overview of Aglet's contributions.

¹² Aglet suggests that SCE shows no need for this planning cycle and any decision issued by 2009 on the next LTPP proceeding would give SCE ample time to readjust its numbers if necessary because of DPV2 problem.