WEM's Alternative Bundled Procurement Plan is our Opening Testimony - a plan for shutting down Diablo Canyon & San Onofre (based on the danger they pose to grid reliability and costs) and replacing that power with energy efficiency and local renewables.
We filed it with an attachment, "Excess Energy with or without Nuclear Power" which used CPUC's Feb. 2011 "Planning Assumptions" to demonstrate an astounding glut of energy - on the order of 50-60% in PG&E territory for all of the next 10 years. The ALJ's ruling ordered everyone to use these Planning Assumptions as the basis of their procurement plans.
5-4-11 WEM's Alternative Bundled Procurement Plan-2 WEM's Opening Testimony in the Long-Term Procurement Proceeding at the California Public Utilities Commission (CPUC)
5-4-11 WEM attachment: CA Excess Energy Without Nuclear
PG&E's Nuclear Costs: PG&E's General Rate Case excerpts
5-10-11 PG&E/Edison Motion to Strike Testimony of WEM & Pacific Environment
5-23-11 WEM Response to PG&E-SCE Motion to Strike
5-23-11 Transcript of CPUC hearing (Motion to Strike)
PG&E and Edison filed a Motion to Strike our testimony ("Motion 9") which had a remarkable number of false allegations, even for them. Our "Response" exposed the falsehoods and also contained some pretty hair-raising passages, including quotes from PG&E's General Rate Case describing the need to replace obsolete and malfunctioning analog equipment responsible for monitoring and controlling the reactor, as well as excerpts from the NRC's closed hearings in 1984 where they decided there was no need to include earthquakes in emergency planning because, in Chairman Palladino's words, "earthquakes are no worse than fog, or whatever..." (see the nuclear section starting on p. 16). Mothers for Peace appealed and Judge Robert Bork denied the appeal, refusing to review the transcripts.
As we explained in our Testimony, this procurement plan is supposed to be a relatively short-term "quick & dirty" plan. It's not supposed to result in any "steel in the ground." At a May 23 hearing the ALJ denied their Motion, though initially he said he was inclined to grant it because the decision should not result in any "steel out of the ground" either. (See EH Transcript starting on p. 26.) We responded that we still need to plan for the event that the nukes are taken offline anyway for retrofits — or if they take themselves offline in an accident — and to make it possible for the Commission to make a sensible decision asap to close them down to prevent serious threats to grid reliability and costs that could result from an accident.
We're trying to couch everything in terms that are within the state's jurisdiction, to get around the "safety" preemption by the NRC. It's challenging to avoid using safety-related arguments, but substituting "grid reliability" covers a lot of the same issues.