BILL ANALYSIS � 1
SENATE ENERGY, UTILITIES AND COMMUNICATIONS COMMITTEE
ALEX PADILLA, CHAIR
SB 43 - Wolk Hearing Date:
April 30, 2013 S
As Amended: April 1, 2013 FISCAL B
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DESCRIPTION
Current law authorizes individual retail, non-residential,
end-use customers to acquire electric service from other
providers in each electrical corporation's (IOU) distribution
service territory, up to the historically highest amount of
kilowatt-hours (kWh) of annual sales for each utility.
Increases authorized in 2009 require a phase-in period for new
customer enrollments of not less than three years and not more
than five years. The program is commonly referred to as "direct
access." (Public Utilities Code 365 et seq.)
Current law establishes a general exception to the cap on direct
access for community choice aggregation (CCA) undertaken by
cities and counties serving their own residents and businesses,
with electricity secured from the market or energy producers
under contract with the CCA to provide service to IOU customers
choosing to enroll. ." (Public Utilities Code 366.2)
Current law requires an electric service provider (ESP) that is
a non-utility entity that offers electric service to customers
within the service territory of an IOU to register with, and be
subject to, the jurisdiction of the CPUC. The ESP is required
to undergo background checks and provide proof of financial
viability and technical and operational ability in addition to
other fees, bonds, and reporting requirements to the CPUC and to
the customer's served. (Public Utilities Code 394 et seq.)
Current law permits local governments who are IOU customers to
generate renewable energy from a facility they own or lease and
credit excess electricity exported to the grid against the
generation charges of that same local government customer's
other facilities. (Public Utilities Code 2830)
This bill eliminates that program.
Current law authorizes the City of Davis to designate
"benefiting accounts" to receive credit for the electricity
generated by a particular photovoltaic electricity generation
facility. (Public Utilities Code 2826.5)
This bill eliminates that program.
This bill establishes the Shared Renewable Self Generation
Program to allow developers of renewable energy, referred to as
providers (aka developers), which are exempted from the
definition of a public utility, to sell renewable electricity
directly to customers of the state's three largest IOUs. The
total capacity cap of interconnected resources would be 500 MWs,
with 100 MWs set aside for residential customers and 100 MWs
reserved for 1 MW facilities located in the state's most
impacted and disadvantaged communities.
This bill permits any customer of any one of the state's three
largest IOUs, identified as "participants" (aka customers) to:
Pay a provider (developer) directly for the costs of
electricity generated by a shared renewable energy
facility;
Receive a credit on the customer's IOU bill for
electricity, at an amount to be calculated by the CPUC,
referred to as the facility rate;
Acquire an interest of up to 2 MW of capacity of a
shared renewable energy facility, except for specified
government entities for which there is no cap;
Pay the IOU for only transmission and distribution
services for the portion of electricity the customer
purchases directly from a developer (the net result based
on a credit the customer would receive equal to the energy
component of the IOU bill); and
Provide a disclosure to any potential program customer
to which the customer intends to sell his/her facility
interest.
This bill requires the state's three largest IOUs to:
Contract with any shared renewable energy facility that
intends to sell electricity directly to the IOU's customers
if the facility is:
o A new eligible renewable resource;
o The 2 MW PVUSA facility in the City of Davis;
o Less than 20 MW in size; and
o Located in the service territory of the IOU
and its customer;
Credit a customer's bill for the energy component of the
customer's applicable electric rate should the customer
choose to purchase electricity from a shared renewable
energy facility;
Credit a customer's bill, on a kilowatt hour basis, at
an amount to be calculated by the CPUC, equal to the volume
of electricity that the customer purchases directly from a
shared renewable energy facility, referred to as the
facility rate;
Purchase excess generation from a developer, for which
they were unable to secure subscribers, at a rate to be
determined by the CPUC equal to the day-ahead price for
electricity. The IOU would receive the renewable energy
credit; and
Provide to the CPUC maps indicating locations where the
addition of capacity would reduce lines loss, lower
transmission-capacity constraints, and defer or avoid
transmission and distribution network upgrades and
construction.
This bill requires the CPUC to:
Establish a facility rate for each shared renewable
energy facility under the program to be used to provide a
credit on the customer's IOU bill so that a customer can
continue to receive distribution and transmission service
from the IOU, but purchase their electricity directly from
a developer;
Base the initial facility rate on the CPUC's cumulative
weighted average time-of-delivery adjusted cost of
electricity reported annually to the Legislature. After a
comprehensive analysis of the costs and benefits associated
with shared renewable energy generation, establish a new
facility rate based on the full value that the renewable
generation provides to non-participating customers;
Revise the facility rate methodology at any time it
concludes that the rate does not provide program
participating with the fair value of electricity and other
benefits produced by the facility or overvalues the
benefits to nonparticipating customers;
Expand the program beyond the 500 MW cap after an
evaluation and revise the program if goals are not being
met;
Develop and enforce disclosures required to subscribers
of a shared renewable energy facility and other rules to
ensure consumer protection. The CPUC would be strictly
prohibited from regulating the prices paid by customers to
the shared renewable energy facility; and
Determine whether direct access customers should
participate in the program.
This bill prohibits:
Charging any participating customer standby or departing
load charges;
The CPUC from regulating the prices paid by a customer
to a developer of a shared renewable energy facility; and
A shared renewable energy facility from being sited on
lands that have been designated, in the last five years, as
prime farmland by the Department of Conservation.
This bill expresses the intent of the Legislature to minimize
the rate impact the Shared Renewable Energy Self-Generation
Program has on nonbeneficiaries, with a goal of ratepayer
indifference but also calls for incremental rate increases as a
result of the program, to be appropriated in a way to allocate
costs, which may include equitable allocation of costs to all
customers on a nonbypassable basis.
BACKGROUND
Deregulation - California's experiment with deregulation was
launched in 1996 when the Legislature passed AB 1890 (Brulte,
1996), to restructure the electric industry. One of the key
features of electrical restructuring was the authorization of
retail competition within IOU service areas. AB 1890 ended the
service monopoly of utilities and authorized retail customers to
purchase energy directly from suppliers. These transactions are
known as "direct access." Community aggregation is a form of
direct access where, for example, a city may act as a purchasing
agent on behalf of its residents.
Before the energy crisis in 2001, non-IOU providers (direct
access providers) had enrolled customers but then failed to
provide the power ordered. The customers returned to the IOUs
for service but the utilities did not have the electric
generation resources to serve those customers because they had
left IOU service. In response a comprehensive framework has
been developed by the Legislature and the CPUC to ensure that,
in the case of direct transactions between energy suppliers and
utility customers, sufficient electric resources are maintained
to serve all customers, that IOU customers not served by
independent suppliers are held indifferent as to the cost
impacts of those transactions, and that the grid is reliable.
Post Deregulation - Two programs remain available for electric
customers to secure power from an entity other than an IOU -
Direct Access and Community Choice Aggregation. It is critical
to note that under these programs the utility is ultimately and
always responsible for providing electricity to every customer
in its service territory if the customer changes his/her mind or
the alternative avenue of purchase used by the customer
terminates or fails to provide service. Consequently both the
CCA and DA programs have been subject to years of painstaking
review, analysis, and litigation at the CPUC to try to provide a
framework under which these alternative mechanisms can operate
and the remaining ratepayers of the IOU are held indifferent as
to the financial impacts of the departing load.
As a result all customers participating in CCAs pay a customer
reliability surcharge; all direct access customers pay a power
charge indifference amount.
IOU "Green Options" - In response to the increasing attention of
the Legislature to institute enhanced renewable purchase options
for electric ratepayers, the three largest IOUs have programs at
varying stages of development to provide customers with greater
access to renewable electricity or renewable energy credits.
San Diego Gas & Electric (SDG&E) and Pacific Gas & Electric
(PG&E) have each have filed applications with the CPUC. Edison
plans to do so later this year.
PG&E - In April 2012 PG&E requested authority from the CPUC
to establish "Green Option" available to all bundled
electricity customers under which customers could
voluntarily choose to pay a rate to purchase Green-e Energy
certified renewable energy credits ("RECs") for a premium
on their utility bill. A heavy amount of criticism was
levied against the program. There was no evidence that the
REC purchases would result in any additional renewable
generation since they would be purchased from existing
in-state solar generators and from wind projects located
elsewhere in the west. It was argued that the plan would
not stimulate new development, or that these purchases
would cause any existing project to generate renewable
electricity that would not have otherwise been produced
and, in short, make no difference. Customers who
subscribed based on the belief that they would cause a net
increase in renewable power production would, in fact, be
misinformed.
The parties in the proceeding (including TURN and the
Sierra Club) negotiated a settlement agreement with PG&E
which was filed in early April to allow PG&E's residential
and commercial customers to voluntarily elect to purchase
renewable power to satisfy up to 100% of their electrical
demand. Under the program, PG&E will execute contracts for
new renewable generation from facilities to be built within
the PG&E service territory sufficient to serve the
electrical demand of customers participating in the
program. The amount paid by participating PG&E customers
will be based on the actual cost of procuring new renewable
generation, thereby providing them with a fair price and a
long-term hedge against rising conventional supply costs.
Non-participating customers will pay no portion of the
costs of the program. The agreement is pending review by
the CPUC.
SDG&E - In January 2012, SDG&E requested authority from the
CPUC to launch a pilot program with two elements designed
to gauge the level of interest among customers for whom
rooftop solar may not be a viable option. Its Share the
Sun? proposal would make up to 10 megawatts (MW) of solar
power available from projects owned by solar developers.
Customers could acquire a portion of the power produced by
a solar-energy system in SDG&E's service area to cover all
or part of their electricity use and receive a bill credit
for the value of the solar power their portion generates.
The "green attributes" of the solar power would belong to
the customer and would not be applied toward SDG&E's
renewable portfolio goals. However, SDG&E would take
delivery of all the energy from these projects, and any
unsubscribed energy will be added to SDG&E's renewable
portfolio, but will be over and above what is procured to
meet the 33 percent renewables target. The second phase of
the program would initiate the "SunRate" in which customers
could have their energy supplied from local solar projects
already under contract to SDG&E. As much as 10 MW would be
available under this "green" rate. Customers would buy the
solar energy from SDG&E to cover 50 percent, 75 percent, or
all of their energy use. The price will be based on the
cost of the solar energy from the local solar projects.
Edison - Is running different models and expects to file an
application for a green option with the CPUC later this
year.
Competitive Procurement v. Fixed Price - Since the restructuring
of the electricity industry in California in the 1990s, the CPUC
has relied on a "competitive market first" approach for the
procurement of electricity. The IOUs develop an annual
procurement plan under which the IOUs solicit bids for
electricity deliveries. The underlying premise of wholesale
competitive procurement is that ratepayers benefit as a result
of lower cost electricity deliveries. Competitive procurement
also underlies the RPS program which requires IOUs to establish
a competitive process to select renewable contracts based on
least cost and best fit. Competitive markets are generally
thought to benefit ratepayers by using competitive pressures to
lower total costs.
Federal Generation Pricing Restriction - The Federal Power Act
grants the Federal Energy Regulatory Commission jurisdiction
over wholesale electric sales in interstate commerce, including
sales made entirely intrastate and sales delivered locally to a
distribution system. The CPUC can set rates but the rate at
which a utility must purchase power from a facility must be:
"Just and reasonable" to consumers;
In the public interest;
Not discriminate against the facility; and
Not exceed the purchaser's incremental avoided cost.
The commission has litigated the issue of generation pricing at
the FERC and based on that proceeding has determined that it can
differentiate renewable pricing for particular sources of energy
(e.g. based-load, peaking) but cannot, under federal law,
establish technology-specific pricing.
COMMENTS
1. Author's Purpose . California offers self-generation of
clean energy through a variety of programs, in order to
allow individuals and companies to exceed the base quantity
of renewable energy in their energy mix. However,
participation in any of these programs requires space to
install self-generation and access to the renewable
resource - which three-quarters of individuals in the state
do not have. Without allowing access to shared renewable
systems, significant numbers of Californians, primarily low
income renters, will remain unable to contribute to
greening our grid or take advantage of the benefit of
renewable generation. We need such a program for
environmental and equity reasons. The existing state
programs are not sufficient.
2. Author's Amendments . The author proposes the following
amendments to address outstanding issues:
Reinstate the Renewable Energy Self-Generation
Bill Credit Transfer program inadvertently repealed by
this bill (PUC 2830);
Reinstate statutory authorization for the
PVUSA solar pilot project to continue in the City of
Davis which was inadvertently repealed by this bill
(2826.5); and
Require the CPUC to review progress toward
meeting the program goals for the most impacted and
disadvantaged communities, and authorize adjustment of
the facility rates and rules for those projects.
Page 25, strike lines 15-17, which strikes the
ability of POU customers that received distribution
service from an IOU to participate.
1. Summary of Program . This bill will allow any ratepayer
in the territories of the three largest IOUs to have their
utility provide two credits on their monthly electric bill
to facilitate the purchase of the customer's electricity
directly from a renewable generator. The first credit would
deduct the cost of generation provided by the IOU. The
second credit would be for kilowatt hours the customer
purchases from a third party but the credit would be based
on a facility rate determined by the CPUC for each facility
enrolled in the program based on the full value that the
renewable generation provides to non-participating
customers. With those two bill credits, the customer can
go to any renewable developer that has enrolled in the IOU
program and buy their electricity from that third party.
The IOUs must contract with any renewable facility within
its territory of less than 20 MW in size to facilitate the
customer's direct purchase of electricity from that
facility (up to an initial statewide cap of 500 MW). As a
result the customer would in essence be paid by the IOU to
contract and pay for renewable electricity directly with
renewable facility. The committee is not aware of any
other utility program that pays the customer to take their
business elsewhere.
2. Facility Rate . What distinguishes this customer
renewable access program from other proposals and those
around the country is that the CPUC would set a "facility
rate" for each facility enrolled in the program to reflect
"the value of that the renewable generation provides to
non-participating customers" but that rate would only be
used as a bill credit to the customer's IOU account. The
utility would not pay the developer; the IOU customer would
contract and pay the developer directly for the cost of
renewable energy they purchase. The developer would report
the purchase in the form of kilowatt hours to the IOU which
would then credit the customer's IOU bill for those
kilowatt hours at the "facility rate" previously determined
by the CPUC in addition to the customer bill credit for
generation.
The author's background refers to the facility rate as the
avoided cost of electricity but the bill requires the CPUC
to "undertake a comprehensive analysis of the costs and
benefits associated with shared renewable energy generation
to determine a facility rate for all facilities
participating in the program that shall be based on the
full value that the shared renewable energy generation
provides." This suggests a rate beyond the avoided cost
and one that would result in a shift of the participating
customer's bill credits to other non-participating
customers. Additionally, this bill requires that 20% (100
MWs) of program capacity be set aside for construction in
locations designated as impacted and disadvantaged
communities by the California Environmental Protection
Agency. If projects do not develop in those locations the
CPUC could increase the rates for any projects in those
areas to ensure that the program goal of development
occurs. Another calculation unrelated to the avoided cost
of generation.
The sponsor of this bill argues that because the developer
is never paid the "facility rate" and that it is nothing
more than a bill credit, the CPUC would not be setting
prices for generation which is against federal law.
Although the facility rate is not a contract price it is
nevertheless an administratively set price for power.
Setting aside the potential violation of federal law, it is
difficult if not impossible to administratively set the
right price for a generation contract and would be a
laborious task for the CPUC with no apparent benefit to
non-participating ratepayers but a great shift of costs as
a result of non-participating customers subsidizing the
subscriptions of participating customers.
3. Stranded Costs/Ratepayer Indifference . Although this
bill expresses legislative intent that there be no cost
shift, the fundamental elements of the bill would result in
non-participating ratepayers, who continue to rely on the
IOU for their electric service, subsidizing the departing
customer's renewable purchases as a result of the bill
credits. Comparable programs (community choice aggregation
and direct access programs) require that the remaining
customers of the IOUs be indifferent as to the costs
associated with the departing load of the CCA or DA
customers. This bill does not meet that standard and
exacerbates the cost-shift by also specifically prohibiting
departing load and standby charges.
4. Consumer Protection . This bill expands the scope of
authority over renewable generators that participate in the
program by requiring them to regulate the relationship
between customers and third party renewable developers
except for the price paid for the renewable generation. As
evidenced by recent hearings of the Senate and Assembly
budget subcommittees, the CPUC is not meeting its current
responsibilities. The addition of new regulatory
responsibilities, particularly those unrelated to consumer
safety do not seem appropriate at this time.
5. Prime Farm Land . This bill restricts the siting of
shared renewable generation facilities on any land
designated as primary farmland by the Department of
Conservation's Farmland Mapping and Monitoring Program
within the last five years "except when the designation has
been reclassified to one congruent to the use of the site
for the purposes of this chapter by either the Farmland
Mapping and Monitoring Program, or via a public process
conducted by the relevant local land use management
planning authority." The California Farm Bureau Federation
writes in opposition to this bill that the restriction does
not go far enough and that the capacity size of projects
should be restricted to those under 3 MW to provide for
more "manageable impacts to important farmland." The land
use restriction proposed by this bill may or may not be
appropriate but it is deserving of consideration in a
separate bill to ensure public notice and review and to
provide the opportunity for review by the appropriate
policy committees of the Legislature.
6. Publicly Owned Utilities . The program proposed by this
bill only applies to customers in the territories of the
state's three largest IOUs. As a result only about
two-thirds of California's ratepayers would have the
opportunity to purchase 100% renewable generation. In the
interest of equity for utility mandates and customer access
to renewables, should the POUs be called upon to institute
comparable programs?
7. Alternative Program Structure . The author's primary
goal is to allow IOU customers who cannot have rooftop
solar or other renewable generation to have a path to
"being green." There are other program models that can
achieve this objective without cost-shifting to
non-participating customers, bogging-down the CPUC in
administering a very complex program, and avoiding the
likelihood of lengthy program challenges to the Federal
Energy Regulatory Commission as a result of the
administrative setting of the facility rate.
The CPUC has program before it in the form of a settlement
agreement between PG&E, TURN, the Sierra Club and other
parties (CPUC A.12-04-020). That program would allow:
PG&E's residential and commercial customers to
voluntarily elect to purchase renewable power to
satisfy up to 100% of their electrical demand. Under
the program, PG&E will execute contracts for new
renewable generation from facilities to be built
within the PG&E service territory sufficient to serve
the electrical demand of customers participating in
the program. The amount paid by participating PG&E
customers will be based on the actual cost of
procuring new renewable generation, thereby providing
them with a fair price and a long-term hedge against
rising conventional supply costs. Non-participating
customers will pay no portion of the costs of the
program. Under the program, PG&E customers such as
tenants who are unable to install rooftop solar will
have the opportunity to participate in a program that
will directly procure additional renewable generation
from resources located within the PG&E service
territory.
The author and committee may wish to consider striking the
content of the bill and amending the bill as indicated in
Attachment A to reflect the model in the above settlement
agreement. This program would provide customers with the
opportunity to purchase up to 100% renewable generation
without shifting the costs of the program to
non-participating ratepayers. This program structure would
have the customer subscribe to the program directly with
the IOU and pay the full cost of the renewable generation
to the utility. The significant difference between the
program structure proposed in this bill and that proposed
in the attached amendments is that the renewable developer
would have no direct relationship with the customer and
would bid in to the IOU's existing renewable procurement
programs for generation under 20 MWs. The generation would
not count toward the IOU's RPS requirements unless the
program had surplus generation for which there were no
subscribers. These amendments are also being considered by
the Assembly Utilities and Commerce Committee at its April
29th hearing of AB 1014 (Williams).
The proposed amendments also have an outreach/marketing
requirement of the IOUs to customers in economically
disadvantaged communities to encourage program
participation. This outreach is in lieu of set-asides for
construction because the existing renewable procurement
programs (Re-MAT and RAM) which would be utilized to meet
the need of program subscribers do not have construction
set-asides and also rely on competitive procurement which
makes it difficult to target generation.
The attached amendments also exclude the siting
restrictions for renewable generation on prime farmland.
8. Double Referral . Should this bill be approved by the
committee, it will be re-referred to the Senate Committee
on Rules for its consideration.
9. Related Legislation .
AB 1014 (Williams) Status: Set for hearing in the Assembly
Utilities & Commerce Committee, April 29, 2013.
AB 1295 (Hernandez) Status: Pending hearing in the
Assembly Appropriations Committee
10. Prior Legislation .
SB 383 (Wolk) Status: Held in Senate Appropriations
Committee, May, 2011 (bill later amended to address an
unrelated issue).
SB 843 (Wolk) Status: Failed passage in the Assembly
Utilities & Commerce Committee August 30, 2012.
POSITIONS
Sponsor:
City of Davis
Support:
AEE Solar, Inc.
American Lung Association
Asian Pacific Environmental Network
California Environmental Justice Alliance
California Rural Legal Assistance Foundation
Clean Power Group
CleanTECH
Coalition for Adequate School Housing
Ecoplexus
El Peco Energy LLC
Everybody Solar, Inc.
Mainstream Energy Corp.
Octus Energy
REC Solar, Inc.
Redwood Coast Energy Authority
Solar Gardens Institute (Washington State)
Sonoma County Board of Supervisors
Sullivan Solar Power
The Vote Solar Initiative
Western Center on Law & Poverty
Support, with amendments:
Department of Defense, Region 9 Regional Environmental
Coordinator
Solar Energy Industries Association
Concerns:
Large-Scale Solar Association
Oppose:
California Farm Bureau Federation, unless amended
Coalition of California Utility Employees
Pacific Gas and Electric Company
San Diego Gas & Electric Company
Southern California Edison
The Utility Reform Network, unless amended
Kellie Smith
SB 43 Analysis
Hearing Date: April 30, 2013
SB 43 (WOLK)
ATTACHMENT A
SUGGESTED AMENDMENTS
2832. (a) The creation of renewable energy within California
provides significant financial, health, environmental, and
workforce benefits to the State of California.
(b) The California Solar Initiative has been extremely
successful, resulting in over 140,000 residential and commercial
onsite installations of solar energy systems. However, it cannot
reach all residents and businesses that want to participate and
is limited to solar. The Green Tariff Shared Renewable
Generation Program seeks to build on this success by expanding
access to renewable energy resources to all ratepayers who are
currently unable to access the benefits of onsite generation.
(c) The Governor has proposed the Clean Energy Jobs Plan
calling for the development of 12,000 megawatts localized
electricity generation by 2020. There is widespread interest
from many large institutional customers, including schools,
colleges, universities, local governments, businesses, and the
military, for development of renewable generation facilities to
serve more than 33 percent of their energy needs.
(d) Public institutions will benefit from a green tariff shared
renewable program's enhanced flexibility to participate in
shared renewable energy facilities.
(e) Renewable generation creates jobs, reduces emissions of
greenhouse gases, and promotes energy independence.
(f) Many large energy users in California have pursued onsite
renewable energy generation, but cannot achieve their goals due
to rooftop or land space limitations, or size limits on net
metering. The enactment of this chapter will create a mechanism
whereby institutional customers such as military installations,
universities, and local governments, as well as commercial
customers and groups of individuals, can efficiently invest in
generating electricity from renewable generation.
(g) It is the intent of the Legislature that a green tariff
shared renewable program be implemented in such a manner as to
facilitate a large, sustainable market for the purchase of an
interest in offsite renewable generation, while fairly
compensating electrical corporations for the services they
provide, without affecting non-participating ratepayers.
2833. (a) On or before March 1, 2014, an electrical corporation
with at least 100,000 customers shall file with the commission
an advice letter requesting approval of a Green Tariff Shared
Renewable Generation Program that it determines is consistent
with the findings specified in Section 2832.
(b) On or before July 1, 2014, the commission shall issue a
resolution on the electrical corporation's advice letter for a
Green Tariff Shared Renewable Generation Program, determining
whether to approve or disprove it, with or without
modifications.
(c) After notice and an opportunity for public comment, the
commission shall approve an advice letter by an electrical
corporation for a Green Tariff Shared Renewable Generation
Program if the commission determines that the program is
reasonable and consistent with the findings specified in Section
2832.
(d) This section does not apply to applications by electrical
corporations for a Green Tariff Shared Renewable Generation
Program that are filed at the commission prior to May 1, 2013,
and does not change the existing authority of the commission to
approve those applications in accordance with its existing
authority under the Public Utilities Code.
The Green Tariff Shared Renewable Generation Program is created
with the following program elements:
Existing procurement mechanisms including the Re-MAT and
RAM be utilized for facilities less than 20 megawatts
capacity;
Allocate 600 megawatts, divided proportionally among the
IOUs and allocated in equal increments over a five year
period in addition to current RPS requirements;
Any single participant is limited to no more than 2
megawatts, except for public entities such as schools,
colleges, universities, local governments, and the
military. Single entity participation cap of 20 percent of
any single calendar year's total capacity;
Participating customers receive bill credits for avoided
generation costs and administrative costs of procuring
renewable resources and charges to fully cover the cost of
the program;
Require that the IOU actively market to low income
customers and minority communities and customers;
In the event of participant attrition, the utility will
apply any additional resources procured for this program to
the IOUs renewable portfolio standard obligation or banked
for future compliance;
Any renewable energy credits associated with this
program are retired on behalf of the participant so that it
cannot be used to count toward an IOU's renewable portfolio
standard compliance goal; specify the disposition of the
REC in the event of attrition, and specify the treatment of
the procurement for purposes of RPS procurement; and
Sunset this tariff in January 1, 2019 unless
reauthorized by the Legislature.