NRG Energy, Inc. (NRG)

NRG discusses its sale of capacity from its existing generation in SP 15 (Los Angeles coastal and San Diego north county) and the repowering of aging units that are expected to be retired in the next ten years. NRG finds it vital to its ability, and that of other independent energy producers, to receive the correct signals from the IOUs' LTPPs to identify their future needs and to initiate the steps necessary to permit and construct new generation, even at existing aging generation sites.

NRG recommends going with the IOUs' forecasts, even if they differ from the CEC's forecasts, because NRG believes the Commission needs to pay attention to the higher forecasts. NRG favors a higher PRM to address forecast uncertainty, poor resource performance and delays in new construction. NRG supports PG&E and SCE's requests for additional procurement authority.

NRG is a proponent of AB 1576 and urges the Commission to promote orderly retirement of existing units to allow for repowering at existing sites. Retirements should not be mandated by arbitrary schedules, NRG argues, but instead should only occur when it is no longer economic for the aging plant to run. RMR contracts can keep a plant running, and aging plants have value as a renewable back-stop.

And finally, NRG promotes a "Competitive Market First"²⁶ policy in which utilities are required to demonstrate that they have solicited market alternatives before being allowed to pursue utility-build or affiliate-built turnkey options. NRG recommends that the Commission ensure that the competitive solicitation of generating resources is equitable and independent from the influence of any competing supplier. From NRG's perspective, the Commission should provide sufficient oversight to the procurement process to ensure fairness, transparency and consistency of utility procurement practices.

²⁶ NRG Opening Brief, p. 30.