Comments on Proposed Decision

The proposed decision in this matter was mailed to the parties in accordance with Section 311 and comments were allowed under Rule 14.3 of the Commission's Rules of Practice and Procedure. Clean Coalition filed comments on February 7, 2012.¹¹ SDG&E filed reply comments on February 13, 2012.

Clean Coalition supports the PD but requests substantial revision to the third of the three types of evidence to support a utility's advice letter showing that the utility reasonably expects that a transmission project will be necessary to facilitate achievement of RPS goals. Clean Coalition proposes that a utility must show that the net cost of the transmission project is not "expected to exceed that required to meet 200% of the RPS net short as identified in RETI 2010 and subsequent updates." ¹² As SDG&E points out, this suggestion does not identify any errors in the proposed decision; rather, it proposes a new policy that was not presented or discussed in the record on which the PD is based. Moreover, on its own merits, Clean Coalition's proposal is not appropriate for an advice letter. The proposal requires a utility's showing in its advice letter to contain at least two elements that are potentially contestable facts: the "net cost" of a project and the "RPS net short." Further, as SDG&E notes, Clean Coalition's proposed requirement that utilities use "RETI 2010 and subsequent updates" as the basis of their calculation does not take into account that there is no timetable for updates to RETI's 2010 work. Clean Coalition's proposed changes to the PD are therefore not adopted.

Minor revisions have been made in the PD to improve clarity and consistency.

¹¹ Clean Coalition's Motion for Party Status was filed February 8, 2012. It was granted February 10, 2012.

¹² Comments at 4.