BILL ANALYSIS                                                                                                                                                                                                    



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          Date of Hearing:   June 24, 2010

                    ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE
                               Steven Bradford, Chair
                    SB 722 (Simitian) - As Amended:  June 22, 2010

           SENATE VOTE  :   (vote not relevant)
           
          SUBJECT  :   Utilities: renewable energy resources.

           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.  Specifically,  this bill:  

          1)Requires the Department of Fish and Game to establish an  
            internal division with the primary purpose of performing  
            comprehensive planning and environmental compliance services  
            with priority given to projects involving the building of  
            eligible renewable energy resources and requires the internal  
            division to ensure the timely completion of plans pursuant to  
            the Natural Community Conservation Planning Act.

          2)States legislative intent to increase the amount of  
            electricity generated from eligible renewable energy resources  
            per year, to that it equals at least 33 percent of total  
            retail sales of electricity in California by December 31,  
            2020.

          3)States a program to increase the quantity of California's  
            electricity generated by renewable electrical generation  
            facilities located in this state.

          4)Permits any existing landfill gas facility approved by a POU  
            prior to September 16, 2009, as a renewable electric  
            generation facility to continue to qualify as an eligible  
            renewable electric generation facility.

          5)Permits a facility that is outside the United States, if it is  
            developed and operated in a manner that is as protective of  
            the environment as a similar facility located in the state, to  
            qualify as an eligible renewable electric generation facility.

          6)Lessens the determination of need for transmission facilities  
            and requires the California Public Utilities Commission (PUC)  
            to make findings that new transmission facilities are  






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            reasonably necessary or appropriate to facilitate achievement  
            of the RPS, requires the PUC to provide assurance that costs  
            that are subject to Federal Energy Regulatory Commission  
            (FERC) jurisdiction are eligible for recovery in retail rates,  
            and requires the PUC to approve an advice letter seeking  
            assurance of cost recovery if the transmission facilities meet  
            specified criteria, or if not less than 50% of the planned use  
            for the capacity of the new transmission line is for  
            interconnecting eligible renewable energy resources.

          7)Makes a legislative finding that delivering genuine renewable  
            electricity to California end-use customers is necessary to  
            improve California's air quality and public health, and  
            California end-use customers may be paying higher rates to  
            achieve the RPS procurement requirements, and that the  
            delivered electricity may be generated anywhere in the  
            interconnected grid that includes many states, and areas of  
            both Canada and Mexico. 

          8)Defines a balancing authority and California balancing  
            authority that includes the California Independent System  
            Operator (CAISO), and a local POU operating a transmission  
            grid that is not under the control of the CAISO.

          9)Requires the PUC to direct each electrical corporation to  
            annually prepare a five-year renewable energy procurement plan  
            as part of a general procurement plan process, and an annual  
            compliance report for prior-year procurement.  

          10)Permits an investor-owned utility (IOU) to apply to the PUC  
            for approval to construct, own, and operate an eligible  
            renewable energy resource.

          11)Requires retail sellers of electricity to procure at least  
            20% of electricity delivered to retail customers from  
            renewable sources by 2013, 25% by 2016, and 33% by 2020. 

          12)Permits the PUC to delay compliance with a RPS requirement if  
            it makes specific findings that there is insufficient  
            transmission to meet the 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).






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          13)Permits the PUC to establish a limitation for each IOU on its  
            expenditures to procure eligible renewable energy resources  
            used to comply with the RPS, and prescribes the elements on  
            which the PUC shall rely.

          14)Requires the PUC to authorize the use of renewable energy  
            credits (RECs) to satisfy the RPS requirements and retires the  
            REC after 18 months from the initial date of generation of the  
            associated electricity or when the retail seller irrevocably  
            retires the REC.

          15)Permits various electricity products from eligible renewable  
            energy resources located within the Western Electricity  
            Coordinating Council (WECC) to count toward specific RPS  
            targets and states a general principle that the resources  
            provide benefits to this state, consistent with least-cost  
            best-fit and project viability principles.  The products and  
            amounts include:

               a.     Not less than 75% from either a new product with  
                 contract executed after June 1, 2010, with a first point  
                 of interconnection with a California balancing authority  
                 or is scheduled from the eligible renewable energy  
                 resource on an hourly or within-the-hour basis into a  
                 California balancing authority without substituting  
                 electricity from another source; or from a product that  
                 has an agreement with a California balancing authority  
                 that allows the balancing authority to dynamically  
                 transfer the electricity product; and,

               b.     Not more than 10% of the products associated with  
                 contracts executed after June 1, 2010, that do not  
                 qualify under the 75% category, and include unbundled  
                 RECs.

               c.     All other renewable energy resources contracts  
                 executed on or after June 1, 2010, not subject to the  
                 other limitation that firm and shape eligible renewable  
                 energy resource products providing incremental  
                 electricity, procured through a contract of not less than  
                 10 years using substitute electricity to balance  
                 schedules meeting specific requirements.

          16)Allows a contract for an eligible renewable energy resource  
            executed prior to June 1, 2010, to count in full toward the  
            procurement requirements if the resource was eligible as of  






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            that date, and if an IOU contract, the contract was approved  
            by the PUC and the approval occurs after June 1, 2010.

          17)Requires the PUC, in consultation with the California Energy  
            Commission (CEC) to report to the Legislature by January 1 of  
            every even-numbered year on the progress and status of  
            procurement activities by each retail seller, the status of  
            permitting and siting of renewable generation and transmission  
            facilities necessary to deliver the renewable electricity, the  
            projected ability of each IOU to meet the RPS, and any  
            barriers to and policy recommendations for achieving the RPS.

          18)Requires the CAISO and the balancing authority of each area  
            in California to work cooperatively to integrate and  
            interconnect eligible renewable energy resources to the  
            transmission grid, and requires the CAISO to seek any  
            approvals from the Federal Energy Regulatory Commission (FERC)  
            that are necessary to accomplish the goals and requirements of  
            the RPS.

          19)Requires POUs to adopt and implement a RPS procurement plan  
            and allows the use of RECs to achieve the following targets:

               a.     Until December 31, 2012, the same percentage as  
                 actually achieved by the utility in 2009;

               b.     20% by December 31, 2013;

               c.     25% by December 31, 2016; and,

               d.     33% by December 31, 2020. 

          20)Requires each POU to report on an annual basis to its  
            customers and to the CEC on specified information regarding  
            price, resource mix, and status in implementing the RPS.

          21)On or before July 1, 2011, requires the CEC in consultation  
            with California Air Resource Board (ARB) to adopt regulations  
            for the enforcement of the RPS on POUs.  Provides that the ARB  
            shall have the authority to impose penalties on POUs for  
            failure to comply with the RPS.

          22)Requires the PUC to annually prepare and submit to the policy  
            and fiscal committees of the Legislature, a written report  
            summarizing all IOU revenue requirement increases associated  
            with meeting the RPS, all costs for infrastructure, any  
            savings experience or costs avoided, all costs for incentives  






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            for distributed and renewable generation, all procurement  
            costs of generation, and an change in the electrical load  
            serviced by an IOU since the preceding report.

          23)Requires the PUC to issue a decision on an application for a  
            certificate within 18 months of the date of filing of the  
            completed application when specified conditions are met,  
            including that the PUC finds it is necessary to provide  
            transmission to load centers for electricity generated in a  
            high priority renewable energy zone or is reasonably necessary  
            to facilitate achievement of the RPS.

          24)Appropriates $322,000 to the PUC for additional staffing to  
            identify, review and approve transmission lines reasonably  
            necessary or appropriate to facilitate achievement of the RPS.

          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 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 the RPS.  If the cost cap  
            is reached, IOUs are not required to sign any additional  
            renewable contract that exceeds the market cost of  
            electricity. 

          6)Requires PUC to develop flexible rules for compliance for the  
            RPS that allows a retail seller that cannot not meet its  






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            annual RPS targets to delay compliance for up to three years  
            and avoid penalties under certain conditions.

          7)Requires the 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 or CPCN).

           FISCAL EFFECT  :   Unknown.

           COMMENTS  :  Over the past few years, there have been a few  
          attempts to increase the RPS.  The author and members of the  
          Assembly have convened numerous stakeholder meetings to try to  
          reconcile divergent concerns over some significant barriers.   
          Some of the most unsurpassable impediments have included cost  
          containment, transmission and siting constraints, the location  
          of eligible generation and whether it's "delivered," and how  
          much flexibility the utilities will be granted given anticipated  
          or unanticipated impediments.  

          The utilities' ability to comply with an increased RPS differs  
          based on geographic attributes of their service territories.   
          While San Diego Gas and Electric is relatively  
          transmission-constricted, any increase in its RPS would need to  
          be both in-basin and reliant on significant transmission  
          investment.  Southern California Edison service territory is  
          replete with sunshine and windy passes, however, to access the  
          huge quantity of renewable energy an increased RPS demands, also  
          requires investment in transmission infrastructure.  PG&E in  
          Northern California, as a gift of geography, just happens to be  
          endowed with a clean and relatively dispatchable watershed in  
          its backyard (RPS eligibility only includes hydroelectric  
          facilities under 30 MW).  Nevertheless, even PG&E needs  
          transmission to increase its RPS to 33%.  To capture all of this  
          requisite renewable energy, the CAISO, responsible for balancing  
          the high-voltage transmission grid, estimates a statewide need  
          for 6 new 500 kV transmission lines to reach 33% RPS.  Just two  
          have progressed beyond the first phase of planning and the  
          determination of need.

           Background :  In 2002, the Legislature approved SB 1078 (Sher),  
          Chapter 516, Statutes of 2002, which created RPS.  Under RPS,  






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          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.  

          Last year, SB 14 (Simitian) and AB 64 (Krekorian) proposed to  
          increase the RPS to 33% by 2020.  Each bill took a different  
          approach, but were similar in overarching goals.  AB 64 was  
          dropped, and the Governor vetoed SB 14 and stated that, although  
          he supports the intent of increasing the RPS to 33% by 2020, the  
          provisions in SB 14 would make achieving that goal difficult and  
          too costly.  The Governor's veto message added that an RPS  
          should provide a streamlined regulatory processes and compliance  
          flexibility that facilitates the timely construction of in-state  
          resources.  Instead of signing SB 14, he preferred to implement  
          an executive order with the same RPS goals and directed the ARB  
          to adopt RPS regulations using its authority for greenhouse gas  
          reduction efforts provided by AB 32 (Nunez), Chapter 488,  
          Statutes of 2006.  The ARB was expected to complete the  
          regulations implementing the 33% RPS by the fall of 2010.  The  
          Governor added that he remains ready to sign legislation that  
          codifies a workable 33% RPS mandate.  

           A balancing act  :  The CAISO is a not-for-profit public benefit  
          corporation formed in 1997 during restructuring of the  
          electricity industry.  The CAISO is responsible for the  
          operation of 25,526 circuit-miles of long-distance, high voltage  
          power lines that deliver electricity throughout most of  
          California and between adjacent balancing authorities,  
          neighboring states, Canada and northern Mexico.  

          The CAISO's principle objective is to ensure the reliability of  
          the California grid, which can become challenging when large  
          amounts of large-scale solar and wind are expected to become  
          more prominent in California's resources mix.  The CAISO must  
          balance the electricity inputs and electricity demand to  
          maintain voltage stability of the grid.  Small hydroelectric,  
          biomass and geothermal generation are more predictable  
          resources, and the integration of these resources into both the  
          markets and operations do not present significant problems.   
          Concentrated solar is an intermittent resource, but the CAISO is  
          less concerned with integrating solar than with integrating  
          wind.  Wind generation is extremely variable and often produces  
          its highest energy output when the demand for power is at a low  
          point.  






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          This bill requires external resources to schedule their output  
          to a California balancing authority in the hour or  
          within-the-hour that they are generating, which creates a  
          must-take requirement at the interchange.  In some intervals,  
          these deliveries could suppress market clearing prices in the  
          CAISO's market and even drive prices negative.  If that were to  
          occur, ratepayers will face contract payments for actual energy  
          as well as additional costs to sell this energy (decrease, or a  
          dec) to balance the voltage.  In some instances, it is also  
          possible that the CAISO may need to curtail interchange  
          schedules, which may create additional concerns under RPS  
          contracts and for purposes of RPS counting.  

           How much will 33% cost  :  In a report providing preliminary  
          results on the feasibility and costs of achieving a 33% RPS by  
          2020, the PUC concluded that such a goal "is highly ambitious,  
          given the magnitude of the infrastructure build-out required."   
          Under the 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 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.

          The PUC's report included the cost of additional transmission to  
          access the remote renewable resources.  The CAISO, in its 2008  
          Report on Preliminary Renewable Transmission Plans, identifies  
          six conceptual transmission projects that, if built and brought  
          on-line by 2020, can help the state meet the 33% renewable  
          standard in 2020 and for several years beyond. These potential  
          transmission projects, intended to connect and deliver renewable  
          resources to the grid, are estimated to cost a total of  
          approximately $6.5 billion (+/- 50% accuracy) in 2008 dollars.  

          SB 14 provided that IOUs would not be required to procure  
          renewable resources that are above the market price of all  
          electricity (market-price referent, or 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" was meaningless and the  






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          contracts exceeded the MPR early in the program.  

          SB 722 would permit the PUC to establish a limitation for each  
          IOU on the procurement expenditures and prescribes the elements  
          on which the PUC must rely when establishing the limitations.   
          The bill requires the PUC to ensure the limitation is set at a  
          level that prevents disproportionate rate impacts, however, it  
          does not define or provide a quantitative definition of  
          "disproportionate."  The bill is only permissive.  In order to  
          ensure cost-containment is mandatory,  this committee may wish  
          to, by not later than January 1, 2016, require the PUC to  
          establish cost limitations, and require the PUC to prepare a  
          report assessing whether each electrical corporation can achieve  
          a 33% RPS by 2020 within the adopted cost limitations.  If the  
          PUC determines that it is necessary to change the limitation, it  
          may propose a revised cap. Absent further legislative action,  
          the proposed modifications may take effect no earlier than  
          January 1, 2017.  If the cost limitation is insufficient, the  
          IOU may refrain from entering into new contracts or to construct  
          facilities beyond the quantity that can be procured within the  
          limitation unless eligible renewable energy resources can be  
          procured without increasing ratepayer costs relative to the  
          procurement of conventional energy resources, and the cost of  
          mitigating greenhouse gas emissions associated with such  
          generation.   

          Some of the parties have suggested additional language that  
          requires the PUC to monitor the status of the cost limitation  
          for each IOU and prescribes action the PUC must take within 60  
          days if it determines that an IOU may exceed its cost  
          limitation.  The additional language also requires the PUC to  
          investigate and identify the reasons why the IOU may exceed its  
          annual cost limitation, and notify the appropriate policy and  
          fiscal committees of the Legislature that the IOU may exceed its  
          cost limitation and the reasons.   This committee may wish to  
          adopt the additional language that requires the PUC to monitor  
          and investigate each utility with regard to the status of  
          reaching the cost limitations, and notify the Legislature.

           In addition, this bill states that California end-use customers  
          may be paying higher rates to achieve the procurement  
          requirements of this article.  In order to ensure the PUC allows  
          only just and reasonable rates,  this committee may wish to  
          strike that provision, and instead replace it with, "the  
          commission shall ensure rates are just and reasonable, and are  
          not significantly affected to achieve the procurement  
          requirements of this article."  






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          The loading order  :  In previous RPS attempts, the term  
          "delivery" was highly debated.  The definition in SB 14 required  
          simultaneous scheduling.  A resource could "deliver" to  
          California if it was either directly interconnected to a  
          California control area or was scheduled into California within  
          the same hour it was produced and from the same location from  
          which it was produced. This requirement would have made it  
          difficult to apply electricity from an out-of-state solar or  
          wind facility toward a utilities' RPS, since many of these  
          resources cannot be scheduled into California at the same time  
          it actually generated.  As a result, the utility could contract  
          with the out-of-state renewable generator but never receive the  
          actual renewable electrons.  The actual generation would need to  
          come from another, usually non-renewable facility, to compensate  
          for the undelivered renewable electricity to "match" the output.  
           

          This bill allows various "electricity products" from eligible  
          renewable energy resources located within the WECC to count  
          toward specific RPS targets.  The bill states a general  
          principle that the resources provide benefits to this state,  
          consistent with least-cost best-fit and project viability  
          principles.  

          Not less than 75% of new renewable energy resources products  
          from June 1, 2010, going forward, must meet the strongest  
          reliability criteria.  This category allows eligibility to  
          products that have a first point of interconnection with a  
          California balancing authority, or are scheduled from a  
          renewable facility on an hourly or within-hourly basis without  
          substituting energy from another source.  SB 722 also allows  
          eligibility for a renewable energy product that allows a  
          balancing authority to "dynamically transfer" the renewable  
          energy product.  This is an attempt to mitigate the problems  
          encountered in SB 14, where California paid to increase its  
          renewable portfolio, but actually received non-renewable  
          generation.  In addition, it is intended to grandfather in the  
          existing contracts that utilities have already signed.  

          This bill attempts to "grandfather in" qualifying RPS contracts  
          that were eligible under the RPS in effect or approved by the  
          PUC as of June 1, 2010.  Some parties have voiced concern that  
          this language does not "grandfather in" existing contracts where  
          minor or technical the terms and conditions may change, or where  
          it might be most feasible for the utility to extend an existing  
          contract.  It is understood that the author will work with the  






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          affected utilities to resolve this issue while keeping within  
          the spirit of the RPS.

           What's a REC  :  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 as a separate commodity 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.   
          This bill limits the amount of RECs and renewable energy  
          products that do not qualify under the interconnected  
          requirement to not more than 10% of the renewable energy  
          products associated with contracts executed after June 1, 2010.   


          Some retail sellers and renewable generators have advocated for  
          broader use of RECs.  They believe that RPS should not limit the  
          use of RECs or put restrictions 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 722 permits the PUC to allow a  
          retail seller to delay compliance with a RPS procurement  
          requirement if it finds that the retail seller has demonstrated  
          that specific conditions have been encountered that are beyond  
          the control of the retail seller.  Some allowable delays include  
          inadequate transmission capacity, unanticipated permitting or  
          interconnection delays, insufficient supply of renewable  
          electricity, or unanticipated curtailment of renewable resources  
          by the balancing authority or transmission owner.  If a retail  
          seller fails to procure sufficient renewable resources to comply  
          with the RPS and the IOU has failed to obtain an order from the  
          PUC authorizing a compliance delay, SB 722 requires the PUC to  






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          exercise its authority to punish the utility in the same manner  
          and to the same extent as contempt is punished by courts of  
          record.  

          Some renewable developers and environmental groups are concerned  
          that there are too many "off-ramps."  They believe that the  
          rules should be stricter and the punishment for noncompliance  
          may not be significant enough of a deterrent to compel the  
          utilities to comply.  The utilities, on the other hand, believe  
          that there should be flexibility because 2020 is 10 years into  
          the future, and it is impossible to forecast all factors that  
          might affect their ability to procure remote and intermittent  
          renewable resources with any accuracy.  Unanticipated  
          consequences are bound to emerge.  

           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 POU 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 722 requires most POUs to meet the 33% RPS by 2020  
          requirement.  While the bill allows the 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, some are concerned that their existing  
          contracts would be precluded from future RPS compliance if they  
          are amended or changed in any way.

           Where are the jobs  :  The renewable energy developers tout  
          job-creation as one of the impetuses for increasing renewable  
          energy procurement to 33% by 2020.  Utilities have job training  
          programs and most utility jobs are relatively good-paying secure  
          jobs.  PG&E has a Power Pathways program that offers programs  
          aimed at producing the skilled workers needed by PG&E and the  
          energy and utility industry.  SCE provided $150 million to 10  
          community colleges to create customized training programs for  
          utility workers.

          The jobs required to site and build the renewable generators may  
          likely be short-term construction jobs.  Most large-scale wind  






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          and solar facilities require very few ongoing maintenance  
          technicians to keep them running.  The solar panel manufacturers  
          state that most of the job creation would be generated in the  
          manufacturing sector, the industries that actually fabricate the  
          solar panels or the wind turbines.  In order to determine  
          whether jobs are truly being created, and whether these jobs  
          include women, minorities, and disabled veterans,  this committee  
          may wish to require the IOUs in their annual reports, to report  
          on the efforts they are taking in recruiting and training  
          employees to ensure an adequately trained and available  
          workforce, including but not limited to, the quantity of  
          new-hires associated with implementing the RPS, the diversity of  
          the trainees and new-hires associated with RPS, and to the  
          extent the information is provided, the same information for the  
          renewable energy generation contracts.  In addition, in its  
          process to develop criteria for the rank ordering and selection  
          of eligible renewable resources, require the PUC to consider the  
          workforce recruitment, training, and retention efforts including  
          the diversity of the employment growth associated with the  
          construction and operation of the eligible renewable energy  
          project.  

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          California Biomass Energy Alliance (CBEA) (if amended)
          California Coalition of Utility Employees (CCUE)
          California Labor Federation
          California State Association of Electrical Workers
          California State Pipe Trades Council
          Large-Scale Solar Association (LSA)
          The Solar Alliance
          Union of Concerned Scientist (UCS) (if amended)
          Western States Counsel of Sheet Metal Workers
           
            Opposition 
           
          California Manufacturers & Technology Association (CMTA)

           Analysis Prepared by  :    Gina Adams / U. & C. / (916) 319-2083