Women's Energy Matters (WEM) and Local Power
WEM and Local Power present a joint brief, but each party makes its own presentation in the brief.
The focal point of WEM's brief is that not enough attention is being paid to energy efficiency in the presentation and review of the IOUS' LTPPs. To begin, WEM sees confusion in EE demand assumptions, and to address this, WEM wants the Commission to require more specific data about where and when energy has been saved and to encourage more interactions between procurement and EE planners. Another concern of WEM's is that due to new evaluation protocols, there is uncertainty whether the IOUs will meet their EE targets.
Next, WEM finds it "exciting and promising"27 that CCAs are planning on quickly achieving 51% renewables and EE, while offering the same or lower prices than the IOUs. To encourage this development, WEM urges the Commission to recognize higher departing load forecasts for CCAs, to avoid cost sharing for stranded costs from over procurement by the IOUs. In addition, WEM is worried that the IOUs are doing "everything they can do [to] smother CCA (and municipalization) in the cradle . . ."28 WEM sees CCAs as opening the door to a much cleaner energy future and urges the Commission to ensure that decisions the IOUs make do not close that door.
WEM also advocates greater integration of EAP loading order preferences in the IOUs' planning so that resources such as EE actually displace supply-side resources. The current situation results in consumers paying twice; once to save energy, and then to provide for a supply of energy-because there is no accurate way now that grid operators know whether energy was saved in a location or time period, and how much. Also, WEM suggests allowing EE to be eligible as peak resources, so the IOUs do not just resort to fossil-fueled plants for this resource.
Local Power is concerned with GHG reductions and compliance with AB 32; compliance with the loading order; accommodating CCA development; compliance with CEC load forecasts; and compliance with RA policies. Principally, Local Power focused on PG&E's procurement request for 2,300 MW of new electric generation. While Local Power discusses a number of reasons that PG&E's request should be denied, the main concern Local Power has is that if PG&E was allowed to commit to this much natural gas resources it could potentially jeopardize CCAs and the market competition and public benefits CCAs could provide. Local Power sees this request by PG&E as evidence that the utility is going in the wrong direction of reducing GHG and promoting 33% renewables. Local Power would prefer to see PG&E fill any need it really has with short term contracts that will provide the flexibility for change in the years to come, especially if more CCAs come into existence. Local Power faults PG&E's model numbers for projected growth of load for CCA. From Local Power's analysis of PG&E's numbers, an erroneous drop in project CCA caused errors in all the data tables, and will affect PG&E's determination of its bundled customer need from 2013 - 2016.
In addition, Local power is disturbed that the IOUs developed plans and scenarios that do not meet the state's targets. And of particular concern to Local Power is the fact that no LTPP conformed to, or even prepares to conform to, GHG reductions as required by AB 32. This deficiency ties into Local Power's concern that if PG&E fills its requested need of 2,300 MW with fossil fueled resources, they will be contributing potent greenhouse gases - especially if PG&E uses LNG, a fuel that has a large upstream GHG emission.
27 WEM/Local Power Opening Brief, p. 1.
28 Id., p. 8.
