March 31, 2020

The California Public Utilities Commission Needs to Plan Now for a Clean, Healthy Future

By Katherine Ramsey and Shana Lazerow

In this time of pandemic, we are seeing the vital power of planning to address or mitigate global emergencies.  

Every two years, the Commission plays a key role in this planning by defining how California’s electric sector will plan for and mitigate climate change, and putting the sector on track to meet the state’s climate targets. It then directs the electricity providers to submit plans showing how they will meet the state’s climate goals. California has emissions reduction targets for both 2030 and 2045—these climate targets were hard fought in the legislature and approved by the Governor. It is the Commission’s responsibility to translate the state’s targets into specific requirements so that the electric sector makes its share of emissions reductions. 

In the 2018 planning cycle, the Commission adopted a 46 million metric ton (MMT) greenhouse gas emissions target for the electric sector, despite alarms from Sierra Club, the California Environmental Justice Alliance (CEJA), and other stakeholders that the Commission’s modeling was drastically at odds with current emissions. We advocated for a far lower emissions target—30 MMT—in order to counterbalance the technical problems and ensure decreases in toxic air pollutants from gas plants. The Commission promised to reevaluate the target in the next cycle. 

The next cycle recently began. But rather than lowering the target, the Commission initially indicated in February that it would adopt the failing 46 MMT target again.  In response, a broad coalition of environmental organizations, environmental justice organizations, the transmission grid operator, renewable energy tech associations, and electricity providers raised the same alarm that the 46 MMT emissions target was too high. Through comments and meetings, many groups explained to the Commission that the target would result in far more actual emissions, increase toxic air pollution for frontline and environmental justice communities, and risk rushed and expensive procurement later. Experts highlighted the Commission’s own analysis that long-term planning requires a target of 30 MMT to consistently build towards the state’s climate goals. Sierra Club and CEJA also asked the Commission to provide a blanket prohibition on new gas generation, explaining that we cannot meet state climate goals if we add gas generation. Coalitions of organizations and thousands of individuals petitioned the Commission to lower its target and similarly urged Governor Newsom to intervene.  

After weeks of public pressure, the Commission took a step toward progress and unanimously approved a revised decision that delays adoption of an emission target, and requires electricity providers to put together two plans: one for a 46 MMT target, and one for a 38 MMT target. The Commission also closed certain loopholes that previously existed for new gas generation, but also created a new loophole for gas projects that run on biomethane. 

This decision makes clear improvements over earlier decision-making: it lays the groundwork for the Commission to adopt a lower target at a later date, recognizes that its modeling is undercounting emissions, and acknowledges the small cost difference between the 46 MMT target and lower targets. The 30 MMT target would cost approximately 5% more than the 46 MMT, and those costs would go towards building new clean energy resources, investing in an industry that is otherwise poised for extensive layoffs due to the recent economic downturn. The 30 MMT target would provide important public health benefits by reducing emissions of toxic air pollutants from California’s gas plants. This target would also be low enough to be far more likely to meet the State’s climate goals, as required by law.

So while the Commission made progress with this decision, incremental improvements like these are not enough for us to achieve our climate targets. Not nearly enough. Sierra Club senior campaign representative Luis Amezcua put it best when he said, “We must go  beyond business as usual, and act with the urgency that is necessary to adequately tackle the climate crisis.”

As Californians electrify their vehicles and homes, additional clean energy will be needed to ensure clean electricity to power those sectors. California’s electric sector needs bold leadership to reach its climate commitments, and this is another year that the Commission did not quite rise to the occasion. 

Katherine Ramsey is a staff attorney at the Sierra Club

Shana Lazerow is the legal director at Communities for a Better Environment