XIII. Role of CCAR

1. Parties' Positions

No party objects to PG&E's proposal to require that GHG reductions for it which contracts meet CCAR protocols, or devote $900,000 in program funding to additional CCAR protocol development. However, CCSF suggests that a greater portion of the A&M budget go to fund protocol development; parties express a desire for CCAR to remain independent from PG&E despite the financial contribution; and parties raise concerns about what to do if CCAR's role in certifying GHG reductions changes or is eliminated.

2. Discussion

We agree that CCAR's involvement in PG&E's program is appropriate. All parties were complimentary of CCAR's work to date. We agree with PG&E that it may file an advice letter to propose use of other high quality project protocols developed by other appropriate entities and approved by the California Energy Commission or the California Air Resources Board, should CCAR become unable to develop project protocols at any time during the three-year CPT program.

The Registry's witness testified that the CPT's provision of funding would not cause PG&E to have undue influence over the Registry, given its governance structure and its established, open methodology for creating and adopting new protocols.⁴³ PG&E does not sit on the Registry's board and is but one of a growing number of Registry members. Further, the CPT's average annual funding for Registry support would amount to no more than $300,000 a year. Given that the Registry testified that its budget in coming years is likely to be about $1.7 million per year, the CPT would represent only about 17%, and the Registry has larger funding sources. We caution PG&E that it shall let the CCAR develop its protocols independently, without regard to where the $900,000 in PG&E's proposal comes from.

As discussed above, a portion of the administrative expenses for the CPT will go to development of new, non-forestry protocols by the CCAR. These protocols will enable PG&E to mitigate the risks involved with limiting its purchase of offsets to a single source. As these protocols are developed, we expect PG&E to expand its portfolio of projects.

⁴³ RT Vol. 1, p. 110-123, Wittenberg, cited in PG&E opening brief at 26.