Californians for Renewable Energy (CARE)

CARE repeats its long standing position that the Commission should support the IOUs making investments in new generation, along with signing long-term contracts, but should also ensure that the cost burdens do not fall on the bundled ratepayers. From CARE's analysis, an IOU owned resource provides service to customers at actual reasonable costs at a regulated return, whereas long-term contracts include non-transparent risk premiums to protect sellers from potential operating risk.¹⁵ In point of fact, CARE questions whether there has been a sufficient demonstration that there is an advantage to the competitive market regime, rather than just following the world of regulated utilities with an obligation to serve receiving cost of service. To this end, CARE suggests that it will scrutinize long-term contracts to see if they serve the public interest, especially the distinct community interests of residential customers who are low income people of color. In addition, CARE plans to review new contracts to determine if they require California Environmental Quality Act (CEQA) review to see if the socioeconomic and environmental impacts of new generation will be considered as part of the bid selection criteria.

¹⁵ CARE Opening Brief, p. 2.