D0510045 - Order Modifying D.04-09-022 and Denying Rehearing, As Modified

4. Energy Action Plan

RACE makes the additional argument that the Phase I Decision is contrary to the Energy Action Plan (EAP). (RACE Application, p. 4.) RACE contends that the Decision "ignores the actions to promote energy efficiency and the development of renewable energy resources and it out of step with the . . . [EAP's] preference for efficiency and renewables." (RACE Application, pp. 8-9.) Furthermore, RACE argues that we have ignored the EAP's "sage advice that effective energy planning be integrated." (RACE Application, p. 9 (emphasis in original).) RACE contends that "[b]ecause the Commission is considering these issues [energy efficiency planning] `separately,' there is inadequate opportunity for efficiency, renewables, and demand-side resources to be taken into account in this proceeding." (RACE Application, p. 9.)

The EAP, which was adopted by the Consumer Power and Conservation Financing Authority (CPA), the CEC, and the Commission, highlights the need for the development of new natural gas supplies for California. RACE is correct in asserting that the EAP emphasizes the promotion of energy efficiency and the development of renewable energy resources. These are issues of great concern to us, as evidenced by the fact that we issued a separate rulemaking, R.01-08-028, where we are "addressing natural gas energy efficiency programs and . . . exploring how to increase demand reduction efforts, including increasing funding for natural gas energy efficiency programs." (D.04-09-022, p. 6.) RACE's contention that we have ignored the EAP's "sage advice" to integrate energy planning is erroneous. The EAP provides that:

The result must be a set of interrelated actions that complement each other, provide risk protection, and eliminate the costs and conflicts that would occur if each agency pursued isolated, uncoordinated objectives. Each agency will need to implement the action plan in its individual proceedings but in concert with each other.

(EAP, p. 3 (emphasis added).) It is clear that the EAP does not require the Commission to address all aspects of energy planning in one proceeding. To do so would be impracticable and inefficient, and therefore contrary to the goals of the EAP. Indeed, we are acting in accordance of the EAP's goals. While we are examining energy efficiency and renewable energy resources in a separate proceeding from this one, we coordinate between the two proceedings and other related proceedings concerning natural gas issues. RACE's logic flounders because we are committed to promoting energy efficiency and renewable energy resources, as evidenced in R.01-08-028. RACE also fails to take into account the fact that we also need to address the State's long-term natural gas needs in other ways, as the CEC's IEPR makes clear.

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