III. DISCUSSION

A. Record and Cost-Effectiveness Issues

The Decision concludes that the SGRP is cost-effective based on Scenario 3, which assumes a 16% higher gas cost than the gas cost used in the base case. (Decision, at pp. 64-66.) According to the Decision, under Scenario 3 the SGRP has a net present value of between $296.7 and $114.7 million. The Decision also notes that if a GHG adder were used to quantify the benefit of avoiding the production of greenhouse gasses the net present value of the project would increase by between $307.9 million and $257.1 million. (Ibid.) After analyzing the claims of various parties, the Decision does not adjust the net present value calculation to reflect claimed "risks and effects" of the SGRP. (Decision, at pp. 17-20, 67.)

The Application asserts that this approach is error for three reasons. First, the Application claims that the number used for the GHG adder has been calculated incorrectly, and deviates from the adders used in other Commission decisions. Second, the Application asserts the Decision failed to reduce the SGRP's net present value to reflect the claimed negative effects of the SGRP. Third, the Application disputes the Decision's conclusion that the SGRP should be evaluated using a high natural gas price scenario. These three claims are discussed in turn, below.