The Utility Reform Network (TURN)

TURN suggests that there are so many issues raised in the proceeding that the Commission should focus on what is needed to be resolved: the adoption of a LTPP for each utility; a determination of any residual need that must be met by conventional resources prior to the next LTPP filing; and revised procurement guidance. In regards to resource needs, TURN suggests that the Commission only concentrate on need through 2013 in this proceeding since the 2008 cycle will allow for readjustments that could reflect changes in the California electricity market. TURN's primary recommendations are summarized as follows:

¬ New conventional resource authorization should be based on the PRM and not based on other justifications or contingencies the IOUs suggest;

¬ Potential increases in CCA or DA will impact future bundled need, but not the physical resource need in the utility service area;

¬ Aging plants should not have an arbitrary retirement date;

¬ Allow utilities to procure a limited amount of new resources beyond the amount needed to meet PRM, but only if those additional resources will reduce the Net Present Value of ratepayer costs when compared with not procuring such new resources;

¬ PG&E has no need in its service area for new resources prior to 2014, and certainly not more than 200 to 700 MW of new conventional procurement;

¬ SCE should not need more than 500 -1,000 MW in its service area, with the net benefits and costs allocated pursuant to D.06-07-029;

¬ Continue with the PRGs and expand them to include DA and CCA customers only when the costs from the RFO will be allocated to those customers pursuant to D.06-07-029;

¬ Continue with the IE, but have the ED, rather than the utility, hire and supervise the IE;

¬ Develop a methodology for evaluating the potential transmission costs avoided by local area generation projects that may eliminate or postpone the need for additional transmission capacity into a constrained area;

¬ Consider allowing the IOUs to use a higher discount rate when evaluating proposed long-term investments;

¬ Adopt TURN's proposal for comparing PPA bids against utility-owned projects and require the utilities to propose a ratemaking mechanism that mitigates the cost and performance risk for these projects;

¬ Adopt TURN's proposal for AB 1576 projects that among other provisions allows repowering projects to participate in utility RFOs for new resources on the same basis as other projects, with some special considerations, but does not have a separate track for AB 1576 projects;

¬ Support the development of a procurement Rulebook for all of the utilities, but as a reference tool and not as a superceding document to Commission decisions and resolutions.