BILL ANALYSIS                                                                                                                                                                                                    



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        SENATE THIRD READING
        SB 14 (Simitian)
        As Amended  September 10, 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)Requires retail sellers of electricity to procure at least 20% of  
          electricity delivered to retail customers from renewable sources  






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          by 2013, 25% by 2016, and 33% by 2020. 

        2)Modifies the definition of eligible renewable resources under RPS  
          as follows:

           a)   Requires renewable generators to deliver electrical output  
             into California by either directly interconnecting with  
             transmission lines controlled by a California transmission grid  
             operator or showing that the metered output of a facility that  
             is not directly connected to a California controlled  
             transmission grid matches hourly import schedules to a  
             California transmission grid operator; and,

           b)   The renewable facility must commence initial operation after  
             January 1, 2010, or the electricity from the facility that  
             commenced operation prior to January 1, 2010, was sold to a  
             retail seller prior to May 31, 2009. 

        3)Eliminates current rules that allow retail sellers to postpone  
          compliance with annual RPS targets for up to three years in the  
          future.  Replaces those rules with provisions that allow the  
          California Public Utilities Commission (PUC) to grant a retail  
          seller the ability to delay compliance for up to two years if PUC  
          makes specific findings that there is insufficient transmission to  
          meet RPS or there were unforeseen delays in permitting or  
          interconnecting projects.  The findings must consider whether the  
          retail seller made all reasonable efforts to construct new  
          transmission and made prudent decisions in procuring resources.   
          The retail seller must also show that it has made all reasonable  
          efforts to procure distributed generation resources and to procure  
          Renewable Energy Credits (RECs). 

        4)Creates a cap on the potential overall cost of the RPS by:

           a)   Requiring PUC to set a Market Price Referent (MPR) to be  
             used to determine above-market costs of renewable electricity.   
             MPR shall be set based on the value of different generation  
             products within a utility's portfolio and the value of current  
             and anticipated environmental compliance costs; and, 

           b)   Providing that an Investor Owned Utility (IOU) does not have  
             to procure additional renewable resources if the total  
             above-market cost of all renewable electricity procured under  
             RPS program or bilateral contracts exceeds 6% of IOUs' total  
             bundled electricity sales. 







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        5)Requires PUC to adopt mechanisms to limit the influence MPR has on  
          how sellers price their renewable proposals and buyers select  
          their contracts.

        6)Creates a mechanism to allow PUC to approve an IOU application to  
          own its own renewable generation and then recover in rates the  
          cost of that generation plus a reasonable rate of return, if PUC  
          finds the renewable generating facility has a reasonable cost and  
          provides a comparable value to ratepayers as compared to other  
          solicitations for eligible renewable resource. 

        7)Allows retail sellers and POUs to use RECs from resources that do  
          not deliver electricity into California (undelivered RECs) toward  
          their RPS obligations, but caps the total amount of undelivered  
          RECs at 25% of the retail seller's or POU's renewable procurement  
          targets.  Provides that if an IOU or POU builds additional utility  
          owned generation, they can increase the allowance of undelivered  
          RECs to up to 30%.

        8)Provides that retail sellers and POUs can count all undelivered  
          RECs from contracts executed by the retail seller or POU prior to  
          September 18, 2009, even if the total amount of RECs exceeds the  
          limits in 7) above.  However, if they exceed the limits above, the  
          retail sellers and POUs could not count additional undelivered  
          RECs toward their RPS obligations. 

        9)Requires PUC to prepare, on a bi-annual basis, reports to the  
          Legislature containing information on the status of meeting RPS,  
          possibilities of retail sellers exceeding caps on above-market  
          costs, overall cost of RPS compliance, and the status of  
          permitting and siting renewable facilities.

        10)Requires POUs to comply with the same RPS mandates as retail  
          sellers and to meet specified public notice and reporting  
          requirements.  Provides that POUs shall retain discretion over  
          specific renewable procurements decisions necessary to meet RPS  
          mandates.  

        11)Requires CEC in consultation with California Air Resource Board  
          (ARB) to adopt regulations for the enforcement of RPS on POUs.   
          Provides that ARB shall have the authority to impose penalties on  
          POUs for failure to comply with RPS.

        12)Creates special procurement rules for several POUs due to their  
          unique circumstances.







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        13)Provides that SB 14 shall not become effective unless AB 64  
          (Krekorian) is also enacted prior to January 1, 2010. 

         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. 

        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  :   






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         1)CEC  :  CEC 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  :  PUC 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:

           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  :  SB 14 is double-jointed to AB 64 (Krekorian) such that  
        for either bill to become effective they both must be approved by  
        the Legislature and approved by the Governor.  The two bills taken  
        together create California's new RPS.  AB 64:

        1)Requires PUC to set minimum levels of renewable procurement all  
          retail sellers must achieve beyond the specified targets to  
          account for the risk that some planned resources will not being  
          developed.  The minimum level could be set at zero.  

        2)Requires renewable procurement plans prepared by IOUs and approved  
          by PUC to include a process to consider the viability of proposed  
          projects when ranking project bids.

        3)Requires PUC to approve an application to build new transmission  






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          lines that are reasonably necessary to develop renewable resources  
          within 18 months of the filing of a completed application, if the  
          new transmission line does not threaten substantial harm to the  
          environment that necessitates a longer time for review under the  
          California Environmental Quality Act (CEQA).

        4)Clarifies that an IOU shall be allowed to recover in rates the  
          costs of constructing transmission lines that will primarily  
          deliver electricity generated renewable electricity and are  
          located in existing transmission rights-of-way or in CEC  
          designated transmission corridor zones.

        5)Requires the Department of Fish and Game (DFG) to establish an  
          internal division for the purpose of performing planning and  
          streamlined environmental compliance services with a priority  
          given to the building of eligible renewable energy resources.

        6)Provides that the California Independent System Operator (CAISO),  
          Sacramento Municipal Utilities District (SMUD) and the Los Angeles  
          Department of Water and Power (LADWP) shall work cooperatively to  
          integrate and interconnect eligible renewable resources to the  
          transmission grid by the most efficient means possible to minimize  
          the impact of and need for additional transmission lines.

         Background  :  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  






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        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  
        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  :  SB 14 provides that IOUs will not be required to procure  
        renewable resources that are above the market price of all  
        electricity (MPR) if the total above market cost of all renewable  
        procurement the IOU executed 6% of the IOUs total revenue  
        requirement for the ten year period leading to 2020.  This cost cap  
        allows the Legislature to determine how much impact renewable  
        electricity should have on a retail sellers' overall cost structure  
        and then set the cost cap at that level by basing it on a percentage  
        of overall revenue.  According to numbers provided by PUC, the new  
        cost cap should allow for close to $17 billion allowable above  
        market costs for PG&E, SCE, and SCE combined.  This is a roughly 20  
        times the amount set aside for above-market costs under current law,  
        depending on the accounting method.

        The language in the bill gives PUC some flexibility to determine how  
        to calculate the cost of individual contracts that expire after 20%.  
         The contracts could be calculated against the cost cap on a  
        pro-rata basis such that only the cost of the contract associated  
        with the years prior to 2020 would count against the cap. 

         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 deliver its  
        electricity to California.  A resource can "deliver" to California  
        if it is either directly interconnected to a California control area  
        or is scheduled into California within the same hour it is produced  
        and from the same location at which it is produced. These  
        definitions ensure that all electricity that is counted toward RPS  
        is actually used to offset the need for non-renewable generation  
        within California. 

        This definition could make it difficult to apply electricity from a  
        solar or wind facility that is located out-of-state to RPS, since  
        many of these resources cannot be scheduled into California at the  
        same time it produced by the resource.  Some of these resources do  






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        not schedule their actual output into California and instead use  
        resources from non-renewable facilities to "match" the output.  Even  
        with this inability for some resources located outside of California  
        to meet the delivery requirements there are approximately 22,000 MWs  
        worth of proposed projects today that are located outside of  
        California that will be able to meet the definition of delivery. 

        SB 14 also allows a retail seller or POU to procure RECs to meet a  
        portion of their RPS obligation. The bill caps the total amount of  
        these RECs at 25% of the total RPS obligation and allows utilities  
        to meet up to 30% if the utilities invest in more utility owned  
        generation.  

        A REC represents the renewable attributes of renewable generation.   
        A REC can remain bundled with the associated energy.  In that case,  
        the utility buys the renewable electricity and uses the RECs to meet  
        its RPS obligation and uses the associated electricity to meet its  
        own load.   RECs can also be traded separate from the underlying  
        electricity (tradable RECs or tRECs).  In this case, one retail  
        seller purchases the 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.

        Some retail sellers and some renewable generators have advocated for  
        broader use of RECs.  They believe 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  :  SB 14 provides that PUC may grant a  
        retail seller that cannot meet its RPS targets an additional two  
        years to meet compliance targets if PUC finds 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. 






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        Publicly Owned Utilities  :  Current law does not require POUs to meet  
        the same RPS that other electricity providers are required to meet.  
        Rather, current law directs each POU to put in place and enforce its  
        own RPS and allows each publicly owned utility to define the  
        electricity sources that it counts as renewable.  No state agency  
        enforces POU compliance or places penalties on a publicly owned  
        utility that fails to meet the renewable energy goals it has set for  
        itself.

        SB 14 requires most POUs to meet the 33% RPS by 2020 requirement.   
        The bill requires each POU to meet the same RPS procurement targets  
        as other retail sellers. The bill allows POUs to comply with the  
        same provisions allowing for up to 30% undelivered RECs to meet  
        their RPS compliance. While the bill allows PUC to adopt rules for  
        REC purchases for retail sellers, POUs should be able to comply with  
        the statutory restrictions on REC purchases without PUC involvement.  


        Most of POUs do not object to creating a specific POU RPS mandate.   
        However, while the largest POU in the state, the Los Angeles  
        Department of Water and Power, supports this bill, most other POU  
        oppose the bill due in large part to their concern that the bill's  
        delivery requirements makes it difficult to procure some resources  
        that had hope to use for RPS compliance. 


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


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