6. Consistency with QF/CHP Settlement and PG&E's Greenhouse Gas Emissions Reduction Target

As discussed earlier, the proposed Amendments were negotiated pursuant to the QF/CHP Settlement and do not become effective until the QF/CHP Settlement effective date. We find that the Amendments are consistent with the QF/CHP Settlement.

6.1. Greenhouse Gas Emissions Reduction Target

Because the Amendments give PG&E the right to schedule the QF facilities, PG&E has the ability to schedule other resources that are more efficient and less GHG-intensive thus reducing GHG emissions and GHG compliance costs. This is consistent with Commission policy encouraging the utilities to consider GHG emissions and costs when making procurement and scheduling decisions.¹² It is also consistent with the Commission's recognition in D.10-12-035 of the benefits of converting an existing QF to a Utility Prescheduled Facility to reduce GHG emissions.

Section 4.8.3.1 of the QF/CHP Settlement provides that amendments to existing QF power purchase agreements that convert to a Utility Prescheduled Facility count towards each utility's GHG Emission Reduction Targets. Section 7.3.1.3. provides that CHP conversion to a Utility Prescheduled Facility counts as a GHG credit.¹³ As the Amendments change these QF facilities to Utility Prescheduled Facilities, they count towards PG&E's GHG reduction targets.

¹² D.07-12-052 at 243-245.

¹³ Emissions reductions are counted as the emissions from the baseline year (as defined in the QF/CHP Settlement), minus the projected power purchase agreement emissions associated with replacing one hundred percent (100%) of the decreased electric generation at a time differentiated heat rate (as defined in the QF/CHP Settlement).