BILL ANALYSIS                                                                                                                                                                                                    Ó          1





                SENATE ENERGY, UTILITIES AND COMMUNICATIONS COMMITTEE
                                 ALEX PADILLA, CHAIR
          

          SB 1332 -  Negrete McLeod                              Hearing 
          Date:  April 17, 2012                S
          As Amended:         April 9, 2012            FISCAL       B

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                                      DESCRIPTION
           

           Current law  requires all investor-owned utilities (IOUs) and 
          publicly-owned utilities (POUs), that serve more than 75,000 
          retail customers, to develop a standard contract or tariff (aka 
          feed-in-tariff or FiT) available for renewable energy facilities 
          up to three megawatts (MWs).  Statewide participation is capped 
          at 750 MWs. 

           Current law  requires the FiT contract price for IOUs to include 
          all current and anticipated environmental compliance costs, 
          including but not limited to, mitigation of emissions of 
          greenhouse gases and air pollution offsets associated with the 
          operation of new generating facilities in the local air 
          pollution control or air quality management district where the 
          electric generation facility is located.

           This bill  requires that the contract price for electricity 
          purchased through a FiT, adopted by specified POUs, include the 
          value of avoided costs of distribution and transmission 
          upgrades, the offset of peak demand and all current and 
          anticipated environmental and greenhouse gas reduction 
          compliance costs and avoided costs.

           This bill  requires that the specified POUs adopt a FiT by March 
          1, 2013.

                                      BACKGROUND
           
          What is a Feed-in-Tariff? - A FiT is a simple, comprehensible, 











          transparent contracting mechanism for small renewable generators 
          to sell power to a utility at predefined terms and conditions, 
          without contract negotiations. For the IOUs, the FiT operates as 
          a "must-take" contract in its portfolio. If the participant 
          generates the power, the IOU must take it and pay for it 
          according to the pre-defined terms of the FiT.

          Small renewable generator FiTs are available in the territories 
          of the three largest IOUs and provide a 10, 15, or 20-year 
          fixed-price, non-negotiable contract for systems sized up to 1.5 
          MW.  The California Public Utilities Commission (CPUC) has a 
          rulemaking open to implement the terms of SB 32 (Negrete McLeod, 
          2009) and expand the IOU FiT to 3 MWs.  The total program 
          allocation between the three IOUs, is approximately 500 MWs.

          Applicable POUs - Current law requires that only the largest 
          POUs adopt a FiT and specifies that those serving a population 
          of 75,000 customers or more make a FiT available to renewable 
          developers in those territories. The affected POUs are: Anaheim, 
          Glendale, Imperial, Los Angeles, Modesto, Riverside, Turlock, 
          and Sacramento.  The total program allocation between the nine 
          POUs is approximately 250 MWs.

                                       COMMENTS
           
              1.   Author's Purpose  .  According to the author "SB 32 did 
               not specify a date by which the covered utilities must 
               begin offering FiT/CLEAN Contracts under this program.  For 
               the IOUs, the CPUC has jurisdiction and is in the process 
               of requiring the launch of the IOU SB 32 programs by 
               mid-2012.  However, there is no comparable agency for the 
               POUs and implementation has varied greatly?SB 32 directed 
               the governing board of each POU to set the price paid for 
               clean energy based on the 'value of each kilowatt hour 
               (kWh) of electricity generated on a time-of-delivery 
               basis.'  However, the definition of 'value' is left up to 
               the discretion of the utility."

              2.   FiT Pricing  .  The author notes that four POUs out of 
               nine have complied with the FiT mandate but that the 
               pricing of the contracts offered varied widely because the 
               bill "didn't provide direction in what should be considered 
               when developing the rate, for example, avoided costs.  This 
               vagueness has led to uneven results in the pricing design 










               of the launched programs and thus participation."

               Four POUs have complied with SB 32 - SMUD priced its FiT at 
               14 cents kWh and is fully contracted; LADWP just announced 
               a 10 MW pilot which will be competitively bid; Riverside 
               offered 5 cents and has had no contracts; and Anaheim's 
               price varies yearly and is based average prices for 
               renewable and non-renewable electricity in state and 
               western electricity markets.    

               The author argues that this disparity of contract offerings 
               and participation between the utilities warrants further 
               direction on contract pricing to stimulate economic 
               development.  Consequently, this bill specifies the 
               components that POUs must consider when calculating the 
               price offered to projects in the FiT program.  Those 
               components include:  avoided costs for distribution and 
               transmission upgrades, offsets of peak demand (if any), and 
               all current and anticipated environmental and greenhouse 
               gas reduction compliance costs, and avoided costs of 
               generation.  POUs opine that these elements would mandate 
               that they increase the offered prices of their FiT and 
               impose unwarranted costs on their ratepayers to meet their 
               RPS goals.

               It is important to note that contracts secured through this 
               pricing mechanism count toward the utility's RPS 
               requirements.  Regardless of how the POU decides to pay for 
               its renewable generation - FiT contract, utility-owned 
               generation, or power-purchase agreements - the POU will 
               still be required to procure the same amount of renewable 
               generation.  To what degree should the Legislature mandate 
               the pricing mechanism used to pay for that renewable 
               generation?


              3.   FiT Deadline  .  In the two-plus years since the FiT was 
               mandated only four POUs have attempted to comply with the 
               SB 32 requirement.  There is no enforcement mechanism for 
               failure to comply with the terms of SB 32.  In response the 
               author has included a deadline of March 1, 2013 for 
               adoption of the FiT program. She states that "without a 
               clear timeframe for program implementation, utilities may 
               continue to delay program development."  It is important to 










               note that there is no penalty under current law if the POU 
               fails to adopt the program and there would still be no 
               penalty on the utility for failure to comply if this bill 
               passes.  With the exception of the RPS statutes, POUs have 
               not been subject to penalties for failure to comply with 
               energy mandates including energy efficiency and the 
               California Solar Initiative.  As a consequence, many 
               utilities have ignored the mandates or interpreted them in 
               ways unintended by the Legislature.

              4.   Technical Amendment  .  Page 4, at the end of line 10, 
               strike "399.20" and insert "399.30." 

                                       POSITIONS
           
           Sponsor:
           
          Clean Coalition

           Support:
           
          American Biogas Council
          Los Angeles Business Council
          Sierra Club California
          Solar Developers Council
          Union of Concerned Scientists

           Oppose:
           
          Southern California Public Power Authority


          










          Kellie Smith 










          SB 1332 Analysis
          Hearing Date:  April 17, 2012