Learning from King Canute: Sea Level Rise Tests the California Public Utilities Commission

King Canute on the Seashore tells the story of the wise 10th century Anglo-Scandinavian King who, tired of sycophantic courtiers that praised him as all-powerful, took his throne to the ocean's edge and ordered the incoming tide to retreat. In answer, the waves washed upon the king's feet and continued to rise, shaming those who claimed he could control even the sea. 

One thousand years later, what will the California Public Utilities Commission (PUC) do when confronted with the rising tide? Southern California Edison (SCE) is seeking PUC approval to meet the vast majority of resource need identified for its Moorpark local capacity area with the Puente project, a new 262 MW gas plant to be owned and operated by NRG. The problem? Puente would be located adjacent to the ocean on a coastal floodplain in the City of Oxnard. As explained by experts retained by the City, the project site is vulnerable to sea level rise and other climate impacts California is currently experiencing and which will increase in severity over the project's lifetime. Indeed, with NASA recently stating current worst-case sea level rise projections may significantly understate the magnitude of future impacts, the City's risk assessment may be conservative. Moreover, SCE's need authorization is to ensure there is sufficient local generation in the event of contingencies such as the loss of multiple transmission lines that prevent power from coming into the area. Because Puente would itself be highly vulnerable to the same severe weather and seismic events that would trigger the need for local capacity, there is significant risk it would be out of service when most needed. 

So how does SCE propose to address the approaching sea? By burying their heads in the sand, urging the PUC to lock in the contract for Puente, and only then having the California Energy Commission (CEC) evaluate sea level rise and related hazards as part of its environmental review of the project. This backward approach has several obvious faults.

First, the PUC is responsible for making sure that major utility investments like Puente are prudent and actually enhance safety and reliability. Understanding climate risk is part of this assessment. As Governor Brown made clear in a recent Executive Order, state agencies like the PUC must "take climate change into account in their planning and investment decisions." The PUC itself has also signaled it has a duty to evaluate climate risk. In announcing a workshop on climate adaption, Commissioner Randolph stated that "we must also take up the challenge of climate resiliency and adaption to ensure that investments in the utility sector take this issue into consideration for the safety and welfare of Californians." Whether or not the PUC approves the Puente contract prior to a full assessment of climate risk at the CEC will indicate whether it takes its commitment to climate adaption seriously.

Second, CPUC approval of the Puente contract would preclude meaningful consideration of project alternatives that should be part of the CEC review process.  NRG’s application for environmental review at the CEC lists the first objective of the Puente project as meeting the terms of its contract with SCE and goes on to state that “alternatives that fail to satisfy the first project objective are neither reasonable nor feasible.”  Because SCE’s contract with NRG locks in project size and location, PUC approval at this premature juncture limits the CEC’s ability to identify more appropriate locations to locate new energy infrastructure. 

As the state has recognized, "priority should be given to actions that both build climate preparedness and reduce greenhouse gas emissions." Increased deployment of distributed energy resources and energy storage is a much more prudent reliability solution consistent with California's climate mitigation and adaptation strategies than proposing to meet almost the entirety of local need with a single greenhouse-gas intensive gas plant at a highly vulnerable location. While awaiting the conclusion of the CEC's environmental review, the PUC should require SCE to issue another request for offers to identify additional clean energy solutions to meet local area need and reduce reliance on fossil fuels. Like King Canute, we can't control the incoming tide, but we can be better prepared for its arrival.