Coalition of California Utility Employees (CUE)

CUE's two main issues in the LTPP proceeding are: (1) CUE wants to remain part of the PRG; and (2) CUE promotes new IOU-owned generation. CUE argues that its participation and contributions to the PRG are valuable and that, contrary to allegations by independent generators, CUE does not just support utility owned, union built projects. CUE desires to remain part of the PRG and requests that the Commission not take any action that would prevent CUE's continued participation.

CUE does tout the benefits of utility-owned generation, and claims to be alignment with the consumer groups on this subject. Specifically, CUE asserts that UOG projects have the following positive attributes; are almost always priced based on cost-of-service; serve utility customers for their entire operating life; are financed under a regulated capital structure designed to provide long-term stability; provide the maximum level of operational flexibility; allow for flexibility viv-a-vis life cycle issues; and allows for different accounting treatment.

CUE claims that only the utilities' competitors oppose utilities owning generation, and even they acknowledge the benefits that utility-owned assets provides to customers. In addition, CUE asserts that UOG helps to mitigate the undesirable effects of the boom-bust cycle that befell California under deregulation.