In UCAN's comments, it explained how 33% RPS assumption underlying the Grueneich alternate imposes more than $24 billion in costs upon the state’s ratepayers – more than 10 times greater than the $1.7 billion cost advertised for Sunrise. And this cost is limited only to the renewable energy that would be accessed in Imperial
Valley due to the addition of Sunrise. It also addresses the blatant misrepresentations made by the CEO of Stirling Energy Systems at the conclusion of the oral arguments, regarding the viability of the 900 Mw Stirling project with and without Sunrise. Finally, UCAN explains how the three “commitments” offered by SDG&E CEO Debra Reed as a compromise in exchange for removing the conditions outlined in the alternate decision are illusory. And the UCAN comments detail how SDG&E has a $96 million annual disincentive to honor its commitment to use Sunrise for renewable energy.

Also, UCAN uses the evidentiary record to debunk the myth that Sunrise will add renewable power to California. The evidentiary record shows just the opposite: Sunrise does potentially promote the development of renewable in the Imperial Valley but only by cannibalizing renewable power that might otherwise be developed in the Tehachapi and Reno regions. Sunrise does not add more renewable power than would otherwise be available to California.

The complete version of UCAN's comments on all of the proposed and alternate decisions can be opened in the attachment below. In the Peevey comments, you can read how he approves a cost of nearly $700 per inch for a new transmission line addition near Alpine Blvd. And you can read about how the Grueneich alternate miscalculates the extent to which SDG&E would use Sunrise (less than 50% of the line's capacity would be used for renewables). Lots of fodder for the insider. Almost incomprehensible to the general public.