Green Power Institute (GPI)

From GPI's review of the IOUs' LTPPs, they are all having trouble reaching the 20% by 2010 renewable goal, which in turn impacts their ability to meet GHG reduction targets. GPI sees the IOUs with only a 70% success rate with their renewable procurement and is concerned that since all LSEs have RPS obligations, there will be fierce competition for the scarce RPS resources and RPS targets will not be met-especially since there is an assumption that 20-30% of their contracted-for new development projects will never achieve operational status.

GPI argues that PG&E might only have 15.2% renewables in its portfolio by 2010, SCE might do better with 17.7%, and SDG&E is making progress but will have to over procure to meet its targets. To address this potential shortfall in renewables, GPI recommends that the Commission use GHG emission reduction as a unifying theme for RPS and EE, and aim for a 33% level of renewables as a means available to the IOUs to reduce their GHG footprints well into the future. "Their success in meeting the RPS mandates will be an important harbinger of their ability to deal with the coming greenhouse gas reduction challenges they will soon be facing."²³

²³ GPI Opening Brief, p. 26.