4. Positions of Parties

In its brief, DRA recommends that the Commission grant PG&E the approval requested. DRA believes that the evidence provided by PG&E indicates that the GWF Transaction is likely to provide both significant ratepayer savings and environmental benefits. DRA point out that if the GWF Transaction is approved in early 2012, PG&E would no longer be obligated to make payments under the existing QF PPAs, resulting in a net savings to customers. In addition, DRA agrees with PG&E that the replacement power under the Peaker PPAs will reduce annual GHG emissions by roughly one-half as compared to emissions from the existing petroleum coke facilities. Because the benefits from the GWF Transaction are greater the sooner the GWF Transaction is approved, DRA recommends that the Commission approve the GWF Transaction without modification.

In his brief, Robert Sarvey contends that the GWF transaction does not provide any ratepayer benefit due to the Henrietta and Hanford PPA's above market costs and the consideration of minimum damage payments. Mr. Sarvey contends that GHG emissions will actually increase globally if the GWF Petroleum Coke Facilities are closed. Mr. Sarvey claims that PG&E has not provided a proper economic assessment of the viability of the QF's under their current contract as required by prior Commission decisions. Despite these drawbacks, Mr. Sarvey concludes that the environmental benefits to the local environmental justice community provide justification for approval of the GWF transaction (despite PG&E's failure to quantify them). However, Mr. Sarvey expresses his concern that these environmental benefits may only be temporary unless the Commission assures that the Petroleum Coke QF's do not repower.