4. Division of Ratepayer Advocates
The Division of Ratepayer Advocates (DRA) filed a timely protest to SCE's application to preserve its right to voice any concerns it might have after completing discovery. In particular, DRA was interested in confirming the cost effectiveness of the contracts and in ensuring that they were chosen after SCE had exhausted its preferred resources and complied with the State's Energy Action Plan (EAP) and the Commission's loading order.
DRA has completed its review of the application and the proffered PPAs and amended its protest to clarify that DRA does not protest or oppose the granting of the relief sought in the application. DRA does not oppose the approval of the four contracts, the need for the contracts, or the cost recovery and allocation of benefits and costs pursuant to D.06-07-029 for the four contracts.
However, DRA amended its protest to correct SCE's understatement of its resource outlook for the time frame 2011 to 2013 when these four new contracts are scheduled to come on-line. DRA notes that this time frame, 2011-2013, will present forecast and procurement uncertainties that make it hard to accurately predict SCE's resource needs during that period. It is during this time period that many Department of Water Resources (DWR) contracts expire, the renewable portfolio standards program (RPS) deadline for the utilities to have additional renewables in their resource portfolio will pass, new transmission lines might be completed and many aging power plants could retire.2
From DRA's analysis of the Need Tables SCE presented with its application, SCE underestimated the proper state of its procurement activities from 2011-2013 after these four contracts are approved. DRA believes that ratepayers would benefit from having SCE's Need Tables as accurate as possible and reflect all Commission authorized need for SCE's service area. DRA is concerned that too much of a resource surplus comes with a cost to ratepayers.
In its amendment to its protest, DRA presents a Need Table that assumes the four contracts subject to this application all come on-line as projected and reflects other resources that SCE had not included in its initial Need Tables.
Since DRA's amendment recommends that the Commission approve all four contracts SCE presented in its application, this application can proceed as an unopposed proceeding. All DRA requests is that SCE's need projections for the time period 2011-2013 accurately reflect the state of SCE's procurement activities after these contracts are approved. SCE does not oppose this request.
Based on SCE's testimony and the accounting provided by DRA, as well as our analysis of the resources authorized in D.06-07-029 and D.07-12-052, when we subtract approved projects, we find that SCE has a range of residual need of 155 MW to 655 MW, without any accounting for contingencies associated with approved resources.
2 DRA Amendment to Protest, August 11, 2008.
