to locations and at times as “deliverable may be necessary to maintain electric service system reliability and local area reliability.” (Decision pp. 12-13) From PD/Florio APD: Club makes a strong argument “Sierra that the Commission should postpone its decision on this matter until the CEC completes its environmental review, a review that Sierra Club suggests could bring forth additional important considerations as related to reliability. Sierra Club suggests that, even if the reliability risk is low, benefits exist to waiting until the CEC’s review is complete, including giving the Commission a comprehensive picture of additional flooding risks and the related reliability concerns.” (PD/Florio APD p. 13). 2. Consideration of Peterman APD p.15-16, 19 Yes. Compare Environmental Justice in (environmental justice is a CEC not Procurement: CPUC issue) Decision p. 16, 19 with (referring to Ordering Paragraph 4 of Sierra Club initially focused its D.13-02-015, reference to D.07-12-052, issues with the Puente project and concluding that future “In on sea level rise risk. procurement applications, we intend to However, Sierra Club was very explicitly consider environmental justice concerned with the issues as part of our review of determination in the Peterman procurement contracts.”) APD that Commission review is limited to and Decision p. 16: and others cite to “economic “CEJA reliability issues” and not D.07-12-052 stating that IOUs to “need environmental justice. Sierra provide greater weight” to criteria Club then provided analysis regarding resource “disproportionate explaining why this siting in low-income and minority determination constituted legal communities and environmental error and was inconsistent with impacts.” Ordering Paragraph 4 of reference to a prior decision calling for EJ considerations in procurement (LTPP Track 1 Decision). (Sierra Club Opening
“deliverable to locations and at times as may be necessary to maintain electric service system reliability and local area reliability.” (Decision pp. 12-13) From PD/Florio APD: “Sierra Club makes a strong argument that the Commission should postpone its decision on this matter until the CEC completes its environmental review, a review that Sierra Club suggests could bring forth additional important considerations as related to reliability. Sierra Club suggests that, even if the reliability risk is low, benefits exist to waiting until the CEC’s review is complete, including giving the Commission a comprehensive picture of additional flooding risks and the related reliability concerns.” (PD/Florio APD p. 13). 2. Consideration of Environmental Justice in Procurement: Sierra Club initially focused its issues with the Puente project on sea level rise risk. However, Sierra Club was very concerned with the determination in the Peterman APD that Commission review is limited to “economic and reliability issues” and not environmental justice. Sierra Club then provided analysis explaining why this determination constituted legal error and was inconsistent with Ordering Paragraph 4 of reference to a prior decision calling for EJ considerations in procurement (LTPP Track 1 Decision). (Sierra Club Opening Compare Peterman APD p.15-16, 19 (environmental justice is a CEC not CPUC issue) with Decision p. 16, 19 (referring to Ordering Paragraph 4 of D.13-02-015, reference to D.07-12-052, and concluding that “In future procurement applications, we intend to explicitly consider environmental justice issues as part of our review of procurement contracts.”) Decision p. 16: “CEJA and others cite to D.07-12-052 stating that IOUs “need to provide greater weight” to criteria regarding “disproportionate resource siting in low-income and minority communities and environmental impacts.” Yes.