Since PG&E’s LTPP was approved by the Commission in 2007, Executive Order S-14-08 accelerated RPS goals. Executive Order S-14-08 now requires that utilities serve their load based with 33% renewable energy by 2020.93 As the Commission recently recognized, “[p]ursuing a 33% target is a policy goal of the Commission and one that should be pursued by the IOUs at this time.”94 The Commission has authority to take all “appropriate action” to ensure that utilities meet this goal.95 Concerns about the reliability and price fluxuation of natural gas have also driven the need for increased renewable procurement.96 The CEC has recommended that the Commission should “mitigate the risk of relying heavily on natural gas by reducing demand for natural gas for power generation through greater reliance on renewable generation.”97 Similarly, the Commission has recognized that “[a] higher renewables mandate would mitigate consumer’ exposure to natural gas price risk likely to come as demand for natural gas intensifies and supply diminishes.”98 Recent estimates show that only 14.4 percent of PG&E’s electricity comes from renewable sources.99 PG&E has consistently failed to meet its RPS goals, and it’s likely that PG&E will not have the required 20% by 2010.100 Despite this, PG&E continues to
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Executive Order S-14-08 (11/17/2008), available at http://gov.ca.gov/executive-order/11072. R.08-08-009 (Dec. 17, 2009); D.09-12-041(Dec. 17, 2009); see also Final Opinion on Greenhouse Gas Regulatory Strategies, D. 08-10-037 at p. 92 (Oct. 16, 2008), available at http://docs.cpuc.ca.gov/word_pdf/FINAL_DECISION/92591.pdf (“We pledge to use our best efforts and to support the efforts of others to achieve 33% renewables by 2020.”). 95 See Cal. Pub. Util. Code § 399.14(e); Cal. Pub. Util. Code § 399.13; § 399.15(a). 96 Re Integration of Greenhouse Gas Emissions Standards into Procurement Policies, D. 08-10-037 at p. 3 (Oct. 16, 2008). 97 Re Policies and Cost Recovery Mechanism for Generation Procurement and Renewable Resource Development Respondents: Pacific Gas and Electric Company, et. al., D. 04-01-050 at p. 65 (Jan. 22, 2004). 98 Re Integration of Greenhouse Gas Emissions Standards into Procurement Policies, D. 08-10-037 at p. 42 (Oct. 16, 2008); see also Ex. 501 (Test of R. Cox) at pp. 8-9 (reliability of wind and solar energy increases with amount and geographic extent of renewable projects). 99 California Public Utility Commission Website, California Renewables Portfolio Standards, available at http://www.cpuc.ca.gov/PUC/energy/Renewables/index.htm. 100 See Ex. 501 (Test. of R. Cox) at p. 11 (citing Commission RPS Quarterly Report (July 94
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