Proposal on Process for Integrated Resource Planning, p. 48, June 28, 2017) Compliance with SB also intend to utilize “We Verified 350 and Other the GHG emissions Relevant State information reported in each Verified Mandates IRP, once approved LSE’s by the Commission, as the Verified Sierra Club supported basis for a mass-based GHG the use of enforceable planning target for that LSE mass-based GHG in the next IRP cycle, emission limits for allowing for necessary 2030, with interim adjustments due to limits for each LSE: (p. 116) Commission “[T]he should only use the While the Commission did GHG Planning Price in not select the 30 MMT the 2017-18 IRP, Scenario that Sierra Club because this IRP must and CEJA supported, the establish mass-based Commission did commit to limits. For the 2019-20 reevaluating the target in IRP, CEJA and Sierra future cycles. Club recommend number of parties favor proposed option “A Staff’s the 30 MMT Scenario in which the because it has the most Commission uses “the beneficial impact on 2030 emissions disadvantaged communities, reported in each LSE’s including CEJA and Sierra preferred portfolio . . . Club, IID, Imperial County, as the basis for a and Range. CEJA and Sierra based GHG planning Club state that they would target for that LSE.” accept the 42 MMT (Opening Comments of Scenario if it was modified California to reflect a true doubling of Environmental Justice energy efficiency savings, Alliance and Sierra lower storage costs, and Club On prioritization of Administrative Law disadvantaged communities Judge’s Ruling by focusing on retirement of Seeking Comment on gas-fired resources to Staff Proposal on minimize air (p. Process for Integrated pollution.” 57) Resource Planning, p. 16, June 28, 2017; see recommended by “As Informal also
Proposal on Process for Integrated Resource Planning, p. 48, June 28, 2017) Compliance with SB 350 and Other Relevant State Mandates Sierra Club supported the use of enforceable mass-based GHG emission limits for 2030, with interim limits for each LSE: “[T]he Commission should only use the GHG Planning Price in the 2017-18 IRP, because this IRP must establish mass-based limits. For the 2019-20 IRP, CEJA and Sierra Club recommend Staff’s proposed option in which the Commission uses “the 2030 emissions reported in each LSE’s preferred portfolio . . . as the basis for a GHG planning target for that LSE.” (Opening Comments of California Environmental Justice Alliance and Sierra Club On Administrative Law Judge’s Ruling Seeking Comment on Staff Proposal on Process for Integrated Resource Planning, p. 16, June 28, 2017; see also Informal “We also intend to utilize the GHG emissions information reported in each LSE’s IRP, once approved by the Commission, as the basis for a mass-based GHG planning target for that LSE in the next IRP cycle, allowing for necessary adjustments due to (p. 116) While the Commission did not select the 30 MMT Scenario that Sierra Club and CEJA supported, the Commission did commit to reevaluating the target in future cycles. “A number of parties favor the 30 MMT Scenario because it has the most beneficial impact on disadvantaged communities, including CEJA and Sierra Club, IID, Imperial County, and Range. CEJA and Sierra Club state that they would accept the 42 MMT Scenario if it was modified to reflect a true doubling of energy efficiency savings, lower storage costs, and prioritization of disadvantaged communities by focusing on retirement of gas-fired resources to minimize air pollution.” (p. 57) “As recommended by Verified Verified Verified based
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