California Large Energy Consumers Association (CLECA)

CLECA's primary concern in its review of the LTPPs is that the IOUs, in their efforts to comply with all Commission decisions and directives on the nature and mix of their resource portfolio and to reliably serve load, have lost focus on cost effectiveness. CLECA reminds the Commission, as it reviews the LTPPs, "to keep in mind its oldest and most basic responsibility-that embedded in Public Utilities Code Section 451-which is to assure ratepayers that they pay rates which are just and reasonable, and just and reasonable rates are those based on the cost to serve."¹⁹ CLECA is concerned that cost effectiveness has become a second or third level issue, after environmental issues and reliability, and does not receive the scrutiny it should to protect the ratepayers.

CLECA also found it difficult to review the individual LTPPs because of the different approaches and formats used. CLECA suggests that the Commission provide clear instructions with respect to the manner in which the IOUs undertake their assessment of need, and their use of different scenarios, to facilitate a comparative analysis of the assumptions used about load and consumption growth. In summary, CLECA is concerned that the LTPPs fail to provide the Commission with an adequate basis upon which to make an evaluation as to whether the recommended plan of each IOU is cost effective.

¹⁹ CLECA Opening Brief, p. 3.