2. Quantification and Consideration of Security And Other Factors

The Application claims that the Decision is in error because it does not consider negative safety and environmental factors in the cost-effectiveness calculation. According to the rehearing Application, the Decision is inconsistent. The discussion of public safety factors states that the Commission will consider "both the GHG adder and the safety, public health, and environmental risks and effects associated with SONGS in out cost-effectiveness evaluation of the SGRP." (Decision, at p. 38.) The Decision's later concludes, at page 68: "Since the record does not quantify any other safety, public health, and environmental risks and effects associated with SONGS, we do not include these factors in the NPV [cost-effectiveness] calculation." According to TURN/CEC, "[i]f the Commission intends to consider [the other factors] ... it must do so." (Application, at p. 6.) The Application also challenges the conclusion that these "other factors" were not quantified and states that they must be included in the cost-effectiveness calculation. (Application, at p. 5.)

These claims do not demonstrate error. The Decision properly considers CEC's testimony on public safety issues-and reaches a different conclusion. (See, Decision at pp. 17-20.) The cost-effectiveness analysis considers three public safety scenarios provided by CEC's witness in Section VII. D. The Decision concludes that CEC's first Scenario is "the most likely," but that CEC's proposed "enhanced security requirements will be imposed in the next few years." (Decision, at p. 19.) As a result, "the first scenario would apply whether or not the SGRP is performed." (Ibid.) The Decision also goes on to say that there is "no basis in the record for estimating the probability of the occurrence of future increased security requirements or their timing." (Decision, at p. 20.) Further, the Decision finds that "the costs estimated by CEC are illustrative examples rather than estimates based on known requirements." (Ibid.)

Following this analysis, the Decision concludes that it should "not adopt CEC's cost estimates" as inputs for the cost-effectiveness model. Instead, "the possibility of future increased security requirements" is used as further support for the conclusion that O&M costs and capital additions must be increased above the amounts forecast by Edison. (Decision, at p. 20.)

Nevertheless, the application is correct where it points out that the Decision's summary of these conclusions at page 67 is incomplete. We will modify the Conclusion section to accurately reflect the previous discussion. The Decision in fact considers other factors to the extent that parties quantified them, but concludes that they should not be made part of the cost-effectiveness calculation.