BILL ANALYSIS                                                                                                                                                                                                    




                                                                SB 14
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        SENATE THIRD READING
        SB 14 (Simitian)
        As Amended  August 18, 2009
        Majority vote 

         SENATE VOTE  :21-16  
         
         UTILITIES & COMMERCE           10-5                 NATURAL  
        RESOURCES                  5-3  
         
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        |Ayes:|Fuentes, Buchanan,        |Ayes:|Skinner, Chesbro, De      |
        |     |Carter, Fong, Furutani,   |     |Leon, Hill Huffman        |
        |     |Huffman, Krekorian,       |     |                          |
        |     |Skinner, Swanson, Torrico |     |                          |
        |     |                          |     |                          |
        |-----+--------------------------+-----+--------------------------|
        |Nays:|Duvall, Tom Berryhill,    |Nays:|Gilmore, Knight, Logue    |
        |     |Fuller, Smyth, Villines   |     |                          |
        |     |                          |     |                          |
         ----------------------------------------------------------------- 
         APPROPRIATIONS      12-5                                        
         
         ----------------------------------------------------------------- 
        |Ayes:|De Leon, Ammiano,         |     |                          |
        |     |Charles Calderon, Coto,   |     |                          |
        |     |Davis, Fuentes, Hall,     |     |                          |
        |     |John A. Perez, Skinner,   |     |                          |
        |     |Solorio, Torlakson, Hill  |     |                          |
        |     |                          |     |                          |
        |-----+--------------------------+-----+--------------------------|
        |Nays:|Conway, Harkey, Miller,   |     |                          |
        |     |Nielsen, Audra Strickland |     |                          |
        |     |                          |     |                          |
         ----------------------------------------------------------------- 
         SUMMARY  :   Increases California's Renewables Portfolio Standard  
        (RPS) to require all retail sellers of electricity and all publicly  
        owned utilities (POUs) to procure at least 33% of electricity  
        delivered to their retail customers from renewable resources by  
        2020.  Makes changes to current renewable procurement rules and  
        procedures for siting renewable generation and transmission.   
        Specifically,  this bill:
         
        1)Replaces the 20% by 2010 RPS target with biennial targets of 20%  









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          by 2012, 23% by 2014, 26% by 2016, 30% by 2018 and 33% by 2020.   
          These targets are applicable to "retail sellers," which include  
          IOUs, energy service providers and community choice aggregators,  
          and also to publicly-owned utilities (POUs).

        2)Revises the definition of "delivery," for purposes of renewable  
          energy generated to meet RPS goal, to eliminate eligibility of  
          energy from an out-of-state resource that is not scheduled for  
          "simultaneous consumption," as defined, by customers in  
          California.

        3)Allows retail sellers and POUs to count the renewable output from  
          renewable facilities that do not comply with the definitions of  
          eligible renewable resources toward RPS if the retail seller or  
          POU had executed a contract to procure resources from a facility  
          prior to May 31, 2009.

        4)Revises existing provisions requiring POUs to implement their own  
          RPS programs by specifically requiring each POU to meet the  
          targets in 1) above and to report annually to the California  
          Energy Commission (CEC) on its progress toward meeting the  
          targets. 

        5)Requires CEC to adopt regulations for enforcement of 4) above, and  
          upon a determination by CEC that a POU has failed to comply with  
          RPS requirements, requires CEC to refer the matter to the Air  
          Resources Board (ARB), which may impose penalties on POU.

        6)Requires PUC to adopt a minimum margin of procurement above the  
          level necessary to comply with RPS to mitigate the risk that  
          renewable projects will be delayed or cancelled.

        7)Sets aside up to one-quarter of the 33% renewable portfolio for  
          IOU-owned generation, by requiring the PUC to approve an IOU's  
          application to construct, own and operate a renewable energy  
          facility until IOU-owned renewable facilities equal 8.25% of IOU's  
          anticipated 2020 retail sales.

        8)Replaces existing RPS flexible compliance provisions with PUC  
          authority to allow retail sellers to delay compliance with the  
          2012, 2014, 2016 and 2018 renewable targets per 1) above for a  
          maximum of two years if the retail seller demonstrates inadequate  
          transmission capacity or unanticipated permitting and  
          interconnection delays.









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        9)Revises the criteria for the Market Price Referent (MPR) used to  
          gauge the reasonableness of renewable energy contracts, by  
          requiring the price methodology to reflect all current and  
          anticipated environmental compliance costs.

        10)Establishes a new and significantly higher annual above-market  
          cap-6% of an IOU's total electric revenues for the prior  
          year-beyond which IOUs would not have to procure additional  
          renewable resources under RPS at above-market costs in a  
          particular year.

        11)Allows retail sellers and POUs to use renewable energy credits  
          (RECs) from out-of-state renewable resources that do not deliver  
          electricity into California (undelivered RECs) toward their RPS  
          obligations, but caps the total amount of undelivered RECs at 20%  
          of the retail seller's or POU's renewable procurement targets.

        12)Requires PUC to approve an application to construct a  
          transmission line within 18 months if the commission finds the  
          project necessary to meet RPS goals.

        13)Requires the Department of Fish and Game to establish an internal  
          division to perform comprehensive planning, streamlined  
          environmental compliance services, and ensure timely completion of  
          Natural Community Conservation Plans related to development of  
          renewable energy projects.

         EXISTING LAW  :  

        1)Requires IOUs and certain other retail sellers to achieve a 20%  
          RPS by 2010 and establishes a process and standards for renewable  
          procurement.  

        2)Provides that POUs are not subject to the same detailed  
          procurement process and standards as IOUs, but are required to  
          implement and enforce their own RPS programs.  

        3)Defines eligible renewable technologies to include biomass, solar  
          thermal, photovoltaic, wind, geothermal, renewable fuel cells,  
          small hydroelectric (30 MW or less), digester gas, municipal solid  
          waste conversion, landfill gas, ocean wave, ocean thermal, and  
          tidal current. 










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        4)Provides that eligible renewable resources that are located  
          outside of California may count toward the California RPS if the  
          generator commences operation after January 1, 2005, and the  
          facility is directly connected to California's transmission grid  
          or the associated electricity is delivered to California. 

        5)Creates a cap on above-market costs of renewable electricity each  
          IOU is required to spend under RPS.  If the cost cap is reached,  
          IOUs are not required to sign any renewable contract that exceeds  
          the market cost of electricity. 

        6)Requires PUC to develop flexible rules for compliance for RPS that  
          allows a retail seller that cannot not meet its annual targets to  
          delay compliance for up to three years and avoid penalties under  
          certain conditions.

        7)Requires the California Energy Commission (CEC) to certify  
          electric generation facilities for the construction and operation  
          of thermal powerplants of 50 MW and larger.

        8)Precludes an electrical corporation from constructing a line,  
          plant, or system without having first obtained a permit from PUC  
          that the present or future public convenience and necessity  
          require or will require such construction, a certificate of public  
          convenience and necessity (CPCN).

         FISCAL EFFECT :   

         1)CEC  :  The commission will require $650,000 annually for two  
          positions and contract funds to expedite the siting of renewable  
          energy generation and transmission.  [Energy Resources Programs  
          Account]

          CEC would also incur annual costs of $600,000 for three positions  
          and contract funds to enforce RPS requirements for POUs. [Energy  
          Resources Programs Account]

         2)PUC  :  The commission states that meeting the 33% by 2020 goal  
          "will require an infrastructure build-out on a scale and timeline  
          perhaps unparalleled anywhere in the world."  In addition to the  
          seven staff current assigned to RPS program, the commission would  
          incur ongoing special fund costs [Public Utilities Reimbursement  
          Account] of $1.7 million for 14 additional positions as follows:










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           a)   Five additional regulatory analyst positions to design and  
             implement the new RPS policies, manage the renewable energy  
             procurement process, coordinate procurement and transmission  
             planning, and calculate program costs for purposes of applying  
             the cost cap;

           b)   An administrative law judge and an attorney to evaluate  
             utilities' requests for flexible compliance with the increased  
             targets; and,

           c)   Seven additional positions, supplementing five existing  
             staff, associated with permitting an anticipated four to six  
             major new transmission projects and within an 18-month deadline  
             following application.

         COMMENTS  :   In 2002, the Legislature approved SB 1078 (Sher),  
        Chapter 516, Statutes of 2002, which created RPS.  Under RPS, IOUs  
        and competitive energy service providers (ESPs) of electricity were  
        required to increase their renewable procurement each year by at  
        least 1% of total sales, so that 20% of their sales are from  
        renewable energy sources by December 31, 2017.  This goal was  
        accelerated to 20% renewable power by 2010 by SB 107 (Simitian),  
        Chapter 464, Statutes of 2006.  
             
        PUC reports that for 2007, IOUs have achieved varying levels of  
        progress toward the 20% goal: PG&E = 11.4%; SCE =15.7%; SDG&E =  
        5.2%.  While each IOU added renewable resources in 2007, the  
        percentage of renewables compared to the rest of the portfolio  
        declined from 2006 due to total load growth. All agencies and  
        stakeholders agree that IOUs will not meet the 2010 deadline.   
        However, PUC reported in October 2008 that IOUs should be in  
        compliance in or around 2013.

        In a recent report providing preliminary results on the feasibility  
        and costs of achieving a 33% RPS by 2020, PUC concluded that such a  
        goal "is highly ambitious, given the magnitude of the infrastructure  
        buildout required."  Under PUC's analysis, the incremental cost of  
        moving from the current to a 33% RPS would result in a 7.1% increase  
        in utility costs.  This increase included the costs associated with  
        more expensive generation resources, new transmission, and other  
        resources that will be needed to provide back up generation when  
        renewable electricity is not available.  The estimate assumes the  
        utilities will continue the same balance of renewable technologies,  
        which includes a large reliance on wind and solar energy, and that  









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        the direct costs of building new renewable facilities remains  
        unchanged over time, and thus does not account for potential  
        technology-related decreases in costs over time.

        Cost cap.  This bill establishes a new limitation for above-market  
        costs for IOU renewable procurement-6% of IOU's revenue requirement.  
         Based on PUC data, for the three largest IOUs, 6% of the 2008  
        revenue requirement equals approximately: PG&E - $650 million; SCE -  
        $700 million; SDG&E - $180 million.  Thus, a rough estimate of the  
        total cost cap for all three IOUs is $1.5 billion at 2008 revenues,  
        roughly between five and 10 times the amount set aside for  
        above-market costs under current law, depending on the accounting  
        method.

        Location, deliverability, and renewable energy credits:  To count  
        toward a retail seller's RPS obligation, the renewable facility must  
        meet several requirements including that the facility be located in  
        California or deliver its electricity to California.  The definition  
        of "deliver" in current law was written to allow an out-of-state  
        renewable generator that wants to serve California load to comply  
        with CAISO rules that require out-of-state electricity to be  
        scheduled into California at specific times and amounts.  Since  
        renewable resources like wind and solar are intermittent, they  
        cannot be scheduled at specific times and amounts.  The intent of  
        the language was for the renewable energy to come to California at  
        some point and then offset the need for fossil fuel generation  
        within California.  However, CEC, which sets the eligibility rules,  
        interpreted the statutory language to allow for transactions where  
        the renewable electricity never comes to California to count toward  
        RPS as an eligible resource.  

        SB 14 changes the definition of delivery to limit the amount of  
        out-of-state generation that can count toward RPS by changing the  
        definition of "deliver."  With the limited exception discussed under  
        the renewable energy credits section below, the new definition  
        requires that electricity from an out-of-state facility that is not  
        directly interconnected to a California control area must be  
        simultaneously scheduled into California.  This means that the  
        renewable electricity must come into California at the same time it  
        is produced or it cannot count toward RPS.  This new definition  
        prevents a utility from counting transactions toward RPS where it  
        purchases wind generation from an out-of-state generator but then  
        sells that electricity to another out-of-state entity and instead  
        imports electricity from a fossil fuel facility.  The new definition  









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        also makes it almost impossible to purchase electricity from a solar  
        or wind facility that is located out-of-state, since these resources  
        cannot be simultaneously scheduled into California.  

        SB 14 allows utilities to use some generation resources that are  
        located outside of California to comply with the RPS requirements by  
        allowing utilities to purchase RECs from out-of-state resources that  
        cannot deliver electricity into California.  A REC represents the  
        renewable attributes of renewable generation.  RECs can also be  
        traded separate from the underlying electricity (tradable RECs or  
        tRECs).  In this case, one retail seller purchases tREC and applies  
        it toward its RPS obligation and another retail seller purchases the  
        associated electricity to meet its own load.  The second retail  
        seller cannot count that electricity toward its own RPS obligations.  
         SB 14 allows California retail sellers to purchase tRECs from  
        out-of-state renewable resources, but caps the total amount of these  
        tRECs at 20% of the retail seller's RPS obligation. 

        Most retail sellers and some renewable generators have advocated for  
        broader use of RECs.  The retail sellers and the Clean Power  
        Campaign state that RPS should not limit the use of RECs or put  
        restriction on the geographic location or deliverability of the  
        associated renewable resource. They believe this broad REC market  
        would give retail sellers more procurement options and could reduce  
        the cost of complying with RPS. 

        A number of environmental groups, the Coalition of Utilities  
        Employees, and California Wind Energy Association have all advocated  
        for a very limited allowance for out-of-state RECs.  They fear that  
        a wide-open REC market will lead to "paper compliance with RPS" and  
        will not result in the construction of any renewable generation  
        within California. 

        Enforcement and off Ramps: Current law also requires PUC to develop  
        rules of flexible compliance that would allow retail sellers to  
        avoid penalties for non-compliance under certain conditions.  The  
        flexible compliance rules allow retail sellers to miss RPS goals in  
        one year provided that it meets that goal within three years.  This  
        means that a retail seller will not be penalized for failing to meet  
        the 20% by 2010 goal if it actually procures 20% of its power from  
        renewable resources by 2013.  A second flexible compliance rule  
        allows PUC to waive penalties for a retail seller if PUC finds that  
        there was insufficient transmission to meet RPS goals. 










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        SB 14 provides that PUC may grant a retail seller an additional two  
        years to meet compliance targets if PUC finds, after an evidentiary  
        hearing, that there is inadequate transmission capacity to meet RPS  
        or there were unanticipated permitting delays for planned eligible  
        renewable electricity projects.  The retail seller must also show  
        that it made reasonable efforts to procure cost effective distribute  
        generation resources and to procure RECs. 
         

         Analysis Prepared by  :    Edward Randolph / U. & C. / (916) 319-2083 


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