Center for Energy Efficiency and Renewable Technologies (CEERT)

CEERT concentrated in its brief on the policy issues related to the IOUs efforts to reduce GHG emissions to 1990 levels and to procure sufficient renewable electric generation to meet 33% of their retail sales by 2020. CEERT argues that a key component of effective GHG reduction is meeting the 33% renewable target. CEERT presents recommendations aimed at revisions to the 2006 LTPPS that would enable the IOUs to achieve those goals. CEERT's review of the 2006 LTPPs concludes that the IOUs will not meet the GHG reductions mandated by AB 32 and will not meet the 33% renewable targets. Originally, CEERT intended to request that the IOUs amend their 2006 LTPPs to reflect GHG implementation rules. However, since the GHG proceeding is still making headway and has not completed the implementation process, CEERT updates its focus to the 2008 LTPP proceeding.

CEERT recommends that the Commission direct the IOUs to include in their 2008 LTPPs three supply scenarios that would achieve the GHG and renewable goals:

¬ A least-cost scenario that reaches a 33% renewable energy component by 2020;

¬ A least-cost scenario that reduces GHS emission levels to the utility's 1990 levels by 2020; and

¬ A least-cost scenario that reduces GHG emission to 90% of the utility's 1990 levels by 2020.