http://www.pacificenvironment.org/downloads/PE%20PGE%20CPUC%20Filing%20April%2014%202010

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a.

The 2009 Peak Reserve Margin in PG&E’s NP26 Territory Fluctuated Between 44 and 46 Percent Demonstrating That PG&E Does Not Need Any New MW. PG&E is required to operate with a 15-17 percent reserve margin.26 In 2009,

California ISO (CAISO) forecasted that PG&E’s NP26 territory would have a 30 percent reserve margin for the summer peak of 2009.27 Even at that level, PG&E would have a reserve margin double what is required.28 However, the actual numbers for the summer demonstrate that PG&E’s NP26 territory actually had reserves margins that never fell below 44 percent (as shown below in Table 1).29 Table 1. Actual Peak Summer Reserve Margins for PG&E NP26 Territory.30 Month

Peak 1-hour load in NP26a (MW)

Date and time of peak

Actual reserve marginb (%)

June 2009

CAISO forecast reserves available in NP26 in summer 2009 (MW) 27,899

19,392

44

July 2009

27,899

19,419

August 2009 September 2009

27,899

19,215

27,899

19,131

6/29/09, 4-5 pm 7/17/09, 4-5 pm 8/10/09, 4-5 pm 9/3/09, 3-4 pm

44 45 46

a) http://oasis.caiso.com/mrtuoasis/?doframe=true&serverurl=http%3a%2f%2ffrptp09. oa.caiso.com%3a8000&volume=OASIS b) (CAISO forecast 1-in-2 reserves-actual peak)/actual peak = reserve margin.

Reserve margins of this magnitude mean that there was an excess of at least 5,527 MW above the required 15 percent reserve margin.31 These excesses show that PG&E already has access to far more generation than is needed, especially when considering the 26

See D.07-12-052 at p. 104. See Ex. 500 (Test. of B. Powers) at p.7 (citing California Independent System Operator, 2009 Summer Loads and Resources Operations Preparedness Assessment, May 7, 2009, at pp. 3-4) . 28 Ex. 502 (Reply Test. of B. Powers and R. Cox) at p. 2(citing California Independent System Operator, 2009 Summer Loads and Resources Operations Preparedness Assessment, May 7, 2009, Table 1, p. 4.). 29 Ex. 502 (Reply Test. of B. Powers and R. Cox) at p. 3. 30 This table is excerpted from Ex. 502 at p. 3. Percents are rounded to the nearest percent. 31 Id. (“19,419 MW x 1.15 = 22,332 MW. This is the actual minimum reserves requirement for NP26 in the summer of 2009. 27,899 MW – 22,332 MW = 5,567 MW. These are the additional reserves that were available in the summer of 2009 in NP26 beyond the 15 percent minimum reserve margin requirement”). 27

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