Natural Resources Defense Council (NRDC)

NRDC's interest in this proceeding is in the "delivery of cost-effective energy efficiency programs, renewable energy resources and other sustainable energy alternatives that reduce the environmental impact of California's energy consumption."²⁵ After reviewing the IOUs' LTPPs, NRDC recommends that the Commission direct SCE to achieve the EE targets as established in R.06-04-010 and not allow SCE to unilaterally change the energy savings targets and to require SCE to provide the information required from the Scoping Memo on whether their absolute GHG emissions will increase or decrease over the next ten years. From NRDC's perspective, utility compliance with the GHG reduction statute will be the most important factor shaping their procurement decisions in the future and asks that the Commission order the IOUs to include some level of GHG analysis in their 2008 LTPP filings.

NRDC argues that in order for California to know whether the IOUs are heading in the right GHG reduction direction, the IOUs must include information on their future planned resource fuel and technology types because each has a different GHG emissions profile. NRDC claims that without this information, we will not have insight into the costs, risks and environmental impacts we can expect from the IOUs' future electricity systems.

²⁵ NRDC Opening Brief, p. 1.