3. PG&E's Arguments

PG&E contends the GWF transaction will provide significant environmental and operational benefits for California. PG&E contends the GWF transaction is reasonable and beneficial for PG&E's customers for the following reasons:

1. As a result of the closure of GWF's five petroleum coke facilities, the GWF transaction will result in a net reduction of GHG emissions of over 600,000 metric tons per year from PG&E's portfolio;

2. PG&E estimates that the GWF transaction will result in a net savings to customers of approximately $15 million as a result of the termination of the existing, higher priced QF PPAs;

3. The Peaker PPAs provide unit-specific dispatch throughout the year. The Henrietta and Hanford facilities are CT units that can provide the operational flexibility to manage changing grid conditions. As the amount of renewable generating capacity grows in response to California's Renewables Portfolio Standard, resources such as the Henrietta and Hanford facilities that are able to respond to changing grid conditions will become even more important. The units will also offer PG&E a range of ancillary services and other capabilities, including spinning reserves, quick start capability, and a large number of starts and operating hours;

4. The Hanford and Henrietta facilities provide local Resource Adequacy (RA) in the Fresno transmission constrained area and will help meet PG&E's local RA requirements during the 10-year contract terms; and

5. The shutdown of the petroleum coke facilities will benefit local communities with specific local and regional environmental improvements. These include the following reductions:

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