Division of Ratepayer Advocates (DRA)
In summary, DRA's mission is to ensure the lowest cost for ratepayers consistent with reliability and safety, but as DRA states, "there are tradeoffs between reliability and costs savings that can not be compromised."21 DRA argues that it carefully scrutinized each IOU's LTPP and makes recommended modifications for unacceptable assumptions underlying the plans.
DRA makes the following recommendations based on its review of the 2006 LTPPs:
1. All IOUs should assume the CEC's IEPR estimates for the other LSEs within their service areas are correct for the IOUs' planning purposes;
2. All IOUs should submit their differences with the IEPR estimates for the IOU's bundled load growth, DA, CCA and other non-utility options, as well as additional demand and load assumptions and forecasts issues to the ED in advance of submitting their plans to facilitate an understanding of the differences among the LTPPs;
3. The IOUS must use the same assumptions for EE, DR and renewables;
4. The IOUs must use the same PRM for their forecasts;
5. PG&E should not get new generation for commercial uncertainties;
6. Any need not approved in this decision should not be entitled to AB 57 protection;
7. ED should employ the IE;
8. The IOUs should be required to submit plans for meeting 33% renewables by 2020, and their incremental cost of doing so, beyond the existing RPS target;
9. SCE does not need any procurement authorization this LTPP cycle;
10. SDG&E does not need a new combined cycle plant this procurement cycle; and
11. The IOUs should do a probabilistic analyses of the carbon risks of their LTPPs.
DRA finds the fact that there is no consistency across the utilities, or even within a utility in the way utilities treat regional and service area needs. This is why DRA recommends that the utilities should not use projections that differ from the IEPR. DRA does a thorough analysis of the ways the IOUs' resource and supply assumptions differ from the IEPR and what impact those differences make on the need determination issues. As an example, DRA believes the use of different procurement projections for DA and CCA in different scenarios serves to askew an IOU's preferred plan in the direction the IOU would like to go. DRA also finds this true in the IOUs' use of scenarios regarding EE and DR target-it makes the scenarios difficult to compare and skews one scenario towards approval more than the others.
DRA also wants the IOUs to use the adopted EE and DR targets, rather than using what they individually determine is a "maximum reliable achievable target."22 In regards to renewable targets, DRA supports the utilities' plans for meeting the 20% target, but notes that the next steps after this target were not presented. And, while DRA is concerned with costs to ratepayers, it challenges the IOUs to ferret out the actual cost of the incremental procurement of renewables from 20% to 33%, instead of simply saying the cost is prohibitive.
And, of great concern to DRA is PG&E's request to increase its procurement to a 1-in-10 peak temperature demand, especially when that request is coupled with contingency amounts as well. DRA recommends reducing PG&E's requested procurement authority by 1,600 MW. DRA applies the same scrutiny to SCE's procurement request and recommends reducing it by 960 MW. DRA recommends only approving the physical need for SDG&E that is needed before 2012 in this planning cycle.
On policy issues, DRA suggests retaining the PRG as a useful forum and suggests that the ED retain the IE. Finally, DRA urges the Commission to direct the IOUs to present a probabilistic analysis of the carbon impact of their plans incorporating the $8 ton price adder.
21 DRA Opening Brief, p. 2.
22 DRA Opening Brief, p. 16.
