BILL ANALYSIS �
SB 43
Page 1
Date of Hearing: June 24, 2013
ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE
Steven Bradford, Chair
SB 43 (Wolk) - As Amended: June 15, 2013
SENATE VOTE : 27-9
SUBJECT : Shared Renewable Energy Self Generation program
SUMMARY : This bill establishes, until January 1, 2019, a
Shared Renewable Self Generation Program (Program) allowing
customers of investor-owned utilities (IOU) to purchase an
interest in a "community renewable energy facility" and receive
a bill credit for the generation component of the customer's
electrical service. Specifically, this bill :
a)Establishes a 500 Megawatt (MW) pilot program until July 1,
2016 for a Shared Renewable Self Generation Program to allow
sellers of renewable energy to sell electricity directly to
customers of the three largest IOUs.
b)Allocates 100 MWs each to residential customers and for 1 MW
facilities located in the disadvantaged communities.
c)Limits each facility to no larger than 20 MW.
d)Exempts sellers from regulation by the California Public
Utilities Commission (PUC) for any prices paid by customers of
IOUs to purchase an ownership interest in a renewable energy
facility acquired through this program. The PUC may enforce
disclosure requirements on the sellers of these facilities and
the PUC may investigate a complaint and enforce consumer
protection.
e)Exempts sellers from certain provisions in State laws that
apply to the sale of securities.
f)Permits any customer of any one of the state's three largest
IOUs to:
1) Pay a seller for electricity generated by a shared
renewable energy facility;
2) Receive a credit on the customer's IOU bill for that
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electricity.
3) Acquire an interest of up to 2 MWs of capacity of a
shared renewable energy facility, except for specified
government entities for which there is no cap;
a)Requires the state's three largest IOUs to:
1) Establish a pilot program of 500 MWs
2) Enter into contracts with sellers so that they may sell
electricity directly to customers of the IOU.
3) Administer bill credits and billing services for the
seller and purchaser of the renewable electricity through
the customer's regular utility services bill.
4) Purchase any electricity generated by the seller that
has not been allocated to a purchaser. The price to be paid
is based on the price known as the default load aggregation
point plus the value of the renewable energy attribute of
that electricity.
5) Provide maps of the utility's distribution service area
to the PUC indicating where the addition of distributed
generation facilities would reduce line loss, lower
transmission capacity constraints, and defer or avoid
transmission and distribution upgrades and construction.
6) Abide by a PUC decision regarding commercial free speech
related to the sellers of facilities and electricity
through this program.
7) Requires, upon request, the IOU to provide
municipalities with data on electricity generation that
occurred within the municipalities' boundaries through this
program.
a)Requires sellers to:
1) Sell electricity from renewable energy facilities
located in the City of Davis or be a newly constructed
facility placed in service after June 1, 2014.
2) Locate the facilities within the service area of the IOU
and its customer.
3) Make specified disclosures to persons who may be
interested in purchasing a share of a renewable energy
facility.
a)Requires customers to:
1) Pay administrative costs to implement the program
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consistent with other existing similar voluntary optional
rate schedules.
a) Requires the PUC to:
1) By January 1, 2015 determine whether customer under
existing alternative electricity purchase arrangements
(Direct Access customers and Community Choice Aggregators)
should participate in the Program.
2) By January 1, 2016 evaluate whether the goals of the
program are being met no later than January 1, 2016.
3) Evaluate the program at any time by its own or by
petition of an interested party and adopt modifications or
rules necessary to ensure the goals are met if those
modifications or rules do not result in costs to
nonparticipating ratepayers.
4) Determine the method of billing and crediting utility
customers.
5) Enforce disclosures required for facility sellers other
rules to ensure consumer protection.
a)Sunsets the provisions of this bill January 1, 2019.
EXISTING LAW
1)California Constitution grants PUC authority to fix rates
charged by public utilities under its jurisdiction. (Article
XII, Section 6, California Constitution)
2)Defines the term "Electric Service Provider" as an entity that
does not include an IOU and establishes a requirement that
Electric Service Providers meet minimum criteria and register
with the PUC. (394 Public Utilities Code).
3)Specifies minimum criteria to disclose civil, criminal, or
regulatory sanctions or penalties imposed within 10 years
prior to registration; proof of financial viability, and proof
of technical and operation ability. (394 Public Utilities
Code)
4)Authorizes the PUC to address consumer complaints regarding
electricity service providers and conduct investigations on
those complaints. (394.2 Public Utilities Code)
5)Establishes a requirement on retail electricity suppliers to
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meet the 33% RPS by 2020 and establishes reporting
requirements for retail sellers of electricity. (399.11 et
seq. Public Utilities Code)
6)Federal law provides the Federal Energy Regulatory Commission
with authority to regulate the sale of wholesale electricity
in interstate commerce.
FISCAL EFFECT : Senate Appropriations estimates the following:
1)Ongoing costs of approximately $250,000 from the Public
Utilities Reimbursement Account (special fund) for two PYs for
program implementation.
2)One-time costs of $150,000 annually for two years from the
Public Utilities Reimbursement Account for an administrative
law judge for the development of necessary regulations.
3)Unknown costs to the state as a ratepayer for nonparticipant
support of the program.
COMMENTS :
1)Author's Statement. "While rooftop solar is a strong and
growing business in California, at least 75% of households
cannot participate because they are renters and don't own
their roofs, they do not have strong enough credit, or their
roof is too small or doesn't receive enough sunlight. The same
is true of most businesses, 70% of whom rent or lease their
facilities. Despite their inability to utilize renewable
energy, these utility customers continue to pay into solar and
renewable programs that fail to benefit them. Additionally,
programs (MASH, SASH, Solar Share, etc.) designed to benefit
low-income or rental utility customers by providing them the
opportunity to utilize renewable energy either have no room
for new participants or fail to provide consumers with access
to affordable renewable energy.
"Moreover, programs set up to offer schools and local
governments an avenue to invest in off-site renewable energy
have proven uneconomical, with too many barriers preventing
projects from penciling out. SB 43 will allow all California
households and businesses the ability to voluntarily buy up to
100% renewable power from a shared facility in their utility's
territory and receive a credit on their current utility bill.
SB 43 is not limited to solar but rather applies to any new
renewable facility up to 20MW in size.
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"SB 43 establishes a pilot program that allows community
renewable energy facilities to sign agreements with utility
customers to sell them renewable energy, without shifting the
cost to customers who choose not to participate and without
spending state money. The pilot program will be capped at
500MW of generation."
2)Similar programs pending approval at the PUC. Two utilities
have filed applications for approval of similar programs at
the PUC:
a) In January 2012 San Diego Gas & Electric (SDG&E) applied
to the PUC for approval to administer a community
renewables program. This application is pending at the PUC.
b) In April 2012 Pacific Gas & Electric applied to the PUC
for approval to administer a Green Tariff Program. In April
2013 Sierra Club California, the National Asian American
Coalition, the Coalition Of California Utility Employees,
Pacific Gas & Electric Company, the Black Economic Council,
the Latino Business Chamber of Greater L.A., the California
Clean Energy Committee, and The Utility Reform Network
(TURN) reached a settlement on the PG&E application. The
settlement would provide for a 250 MW program that would
procure power from new renewable facilities and provide
100% renewable power to customers who voluntarily elect to
participate. The amounts paid by the customers would be the
actual cost of the new renewable generation. Customers who
do not elect to participate would pay no costs for this
program.
It is unclear if it is the intent of the author to:
add the 500 MW program specified in SB 43 to the
combined 350 MW programs pending at the PUC
terminate the pending applications at the PUC
merge the provisions of SB 43 with the applications
pending at the PUC
The author may wish to modify SB 43 so that the program
design in SB 43 is similar to the settlement reached in the
PG&E Green Tariff application. This approach would maintain
the goal of SB 43 to reach those customers who would like
to receive electricity from renewable sources but are
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unable to participate in existing programs.
Provisions made for the City of Davis, market the program
to low-income and minority communities and customers, and
fulfilling municipal data requests in SB 43 can be included
in the amendments.
1)Cost shift. The term "cost shift" refers to when a ratepayer
funded program relies on nonparticipating utility customer to
pay for programs that meet the needs of a subset of all
utility customers.
This bill includes a provision where an IOU must purchase all
electricity produced by a seller if the seller has not found a
willing customer to purchase that electricity. This provision
mandates an electric utility to purchase the power whether it
does or does not need the power and specifies that the payment
for that power be at the same rate as the "default aggregation
load point plus the value of any renewable energy credits."
The PUC has mandated that IOUs enter procure sufficient power
to meet 115% of projected electricity demand. In addition,
IOUs are mandated to procure electricity to meet the
requirements of the schedule set forth in the Renewable
Portfolio Standard. The cost of electricity purchases are
passed through to all ratepayers. The mandate to purchase the
unallocated generation from the community renewable facilities
represents a cost shift to nonparticipating ratepayers.
2)Securities Law Exemption. SB 43 includes an exemption from
California Corporation Code that, according to the author,
eliminates the need for costly securities permitting for
entities that sell or trade rights to bill credits or
interests while retaining consumer protections available under
the anti-fraud provisions of the Securities Law.
However, this exemption also excludes sellers from important
protections before entering into an arrangement to purchase
bill credits or interests, specifically the requirement in the
Corporation Code that would ensure that a purchaser is
qualified to purchase bill credits or interests, or if the
seller is qualified specifically:
This exemption does not provide protections that would
determine whether the entity or individual has the net worth
to enter into such an agreement or has received information
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indicating the name, suitability of the seller, the financial
stability of the seller, disposition of the shares, whether
any relevant judgments have been against the seller or its
officers or directors, and other provisions to protect
purchasers from inappropriate risks.
3)Unclear Language in the Bill. Several parts of the bill do not
appear to clearly state the intent of the author while parts
of bill appear to be in conflict with each other. Several
examples are:
a) Default Load Aggregation Point Price. In the definition
section of SB 43 it defines the default aggregation load
point price as a commission-determined day-ahead price for
electricity.
This value is to be used later in SB 43 as one of the
components in a mandatory price for a generation that must
be purchased by an electrical corporation from the facility
developer in the event that the developer has not been able
to sell all of a facility's generation to subscribers.
The day-ahead market varies (on a daily basis) based on
near term forecasts for electricity demand and supplies of
electricity available to meet that demand.
The day-ahead market for electrical corporations affected
by SB 43 is administered by the California Independent
System Operator.
It is not likely that the author intends for the PUC to
determine daily day-ahead prices for electricity.
b) Allocation of costs. In Section 2833(j)(2)(A) the bill
states that the commission shall determine the appropriate
method of allocation costs to implement the program. In
2833(j)(2)(B) the bill states that the participating
customers shall pay the administrative costs.
It is unclear if paragraph (A) what is meant by the PUC
determining the method of allocating costs and how the
commission is to use this together with paragraph (B).
c) Maximum Program cap. In Section 2833(d) SB 43 specifies
a pilot program cap of 500 MW for an 18 month period ending
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July 1, 2016. Elsewhere the bill sunsets the program on
January 1, 2019. As written it is unclear if this bill is
intended to allow the PUC to increase the program cap on
its own accord (assuming the 500 MW pilot is fully
allocated by July 1, 2016 or if the author intends that the
Legislature increase the cap.
According to the author it is the intent that the cap be
500 MW unless the Legislature increases the cap.
d) All otherwise applicable charges. SB 43 allows a bill
credit that can be used against the generation portion of
the participant's utility bill. Implied in this is that the
participant would remit for all charges that are not
generation. However, since most charges are based on the
amount of electricity delivered (called volumetric charges)
it is not clear, as drafted, whether the author intends for
those volumetric charges to be calculated before or after
the bill credit is applied.
According to the author, in order to ensure that there are
no costs shifted to nonparticipating ratepayers as a result
of this program, the intent is for the volumetric charges
to be calculated before the bill credit is applied to
ensure that participants are responsible for all otherwise
applicable charges.
e) Relationship to Net Metered Tariffs. As drafted, this
bill allows a bundled customer of an IOU to participate in
this program. It is unclear whether a customer who is on a
net metering (NEM) tariff would be billed for costs and
charges assessed through participation in this program that
the NEM statute exempts that customer from paying.
f) Excess generation from a NEM facility. It is unclear if
excess generation from a facility on a NEM tariff is
allowed to be sold through this program. As this scenario
is currently not contemplated by this program,
consideration for such an arrangement should only be
considered if proposed by separate legislation.
g) Minimum facility size. As drafted this bill would limit
facilities to no larger than 20 MW, except in specified
circumstances facilities are limited to 1 MW. This bill
does not establish a minimum facility size.
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1)Related Legislation.
SB 383 (Wolk, 2011), bill was amended to address a subject
unrelated to community renewables.
SB 843 (Wolk, 2012), died in Assembly.
AB 1014 (Williams, 2013), held in Senate Rules
AB 1295 (Hern�ndez, 2013) in Senate Energy, Utilities, and
Communications Committee
2)Suggested amendments.
The author may wish to consider amendments to eliminate cost
shifts to nonparticipating ratepayers, to address the
disposition of similar programs pending approval at the PUC,
and clarify the program cap. In addition, the author may wish
to consider the following amendments to add specific
allocations to specified communities and other clarifications
as specified:
Modify language regarding legislative intent to
reinforce that it is the intent of the Legislature that
this program will not result in shifting of costs to
nonparticipating ratepayers.
Revise program to establish a voluntary programs where
utilities would procure renewable generation in response to
customer who voluntarily elect to participate. The
participants would pay for the cost of the program (energy
and other costs). Customers who do not elect to participate
would pay no costs for this program.
Add language regarding treatment of an application by an
electrical corporation for a similar program that has
already been made to the PUC but is not yet approved.
Reserves a minimum of 100 MW for facilities to be
located within environmental justice areas and specifies
that these facilities be small, 1 MW, and reserved a
portion for residential customers.
Specifies that no less than 100 MW of this program shall
be reserved for residential customers
Reserves 20 MW for City of Davis
Add language specifying that a participating customer's
rates will be credited with any other commission-approved
costs or values applicable to the renewable resources
contained in this program's portfolio. These additional
costs or values will be applied to a new customer when they
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initially subscribe.
Add language retiring GHG credit values on behalf of the
participants
Preserve provision allowing utilities to provide
municipalities, upon request, data on program generation in
their communities, subject to privacy limitations.
Strike amendments to Corporations Code and Sections 216,
218, and 365.1 of the Public Utilities Code.
Specifically:
Strike lines 1 through 8 on Page 2
Strike pages 3-30
Insert:
Chapter 7.6 (commencing with Section 2831) is added to Part 2
of Division 1 of the Public Utilities Code, to read:
CHAPTER 7.6. Shared Renewable Energy Self-Generation Program
The Legislature finds and declares all of the following:
(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 will achieve its goals,
resulting in over 150,000 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. A green tariff shared renewable
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) 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
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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 serve
their needs with renewable generation.
(g) It is the intent of the Legislature that a green tariff
shared renewable program be implemented in such a manner that
facilitates a large, sustainable market for offsite renewable
generation, while fairly compensating electrical corporations
for the services they provide, without affecting
nonparticipating ratepayers.
(h) It is the further intent of the Legislature that a green
tariff shared renewable program be implemented in such a
manner that ensures nonparticipating ratepayer indifference
for the remaining, bundled service, direct access, and
community choice aggregation customers.
2831. (a) On or before March 1, 2014, an electrical
corporation with at least 100,000 customers shall file with
the commission an application requesting approval of a green
tariff shared renewable program that the electrical
corporation 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 application for a
green tariff shared renewable program, determining whether to
approve or disapprove it, with or without modifications.
(c) After notice and an opportunity for public comment, the
commission shall approve an application by an electrical
corporation for a green tariff shared renewable program if the
commission determines that the program is reasonable and
consistent with the findings specified in Section 2832.
(d) This chapter shall not apply to electrical corporations
that have filed an application for a green tariff shared
renewable program at the commission prior May 1, 2013 provided
the commission approves the application with a determination
that the program does not shift costs to non-participating
customers and the application is consistent with this chapter.
(e) Notwithstanding (d) the commission may approve an
application that, by May 1, 2013, has reached a settlement
agreement. The commission shall, within a reasonable time,
require revisions to a settlement agreement previously adopted
to be consistent with this chapter.
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2832. In implementing this chapter, the commission shall
require a green tariff shared renewable program to be
administered in accordance with this section.
(a) Electrical corporations shall use existing
commission-approved tools and mechanisms to procure additional
renewable energy resources, as defined in Section 399.12, from
incremental, additional renewable generation facilities, sized
20 megawatts and below.
(b) An electrical corporation shall make the tariff available
to customers within the service territory of the electrical
corporation until the electrical corporation meets its
proportionate share of a statewide cap of 600 megawatts of
customer participation. The proportional share shall be
calculated based on the ratio of each electrical corporation's
retail sales to total retail sales by electrical corporations
with at least 100,000 customers. The commission may place
other restrictions on the availability of the tariff, such as
restricting participation to a certain level of capacity each
year. The following restrictions shall apply to the statewide
cap:
(1) 100 megawatts shall be reserved for facilities located in
areas previously identified by the California Environmental
Protection Agency as the most impacted and disadvantaged
communities. These communities shall be identified as census
tracts that are identified within the top 20 percent of
results from the best available cumulative impact screening
methodology by considering the following categories:
(A) Areas disproportionately affected by environmental
pollution and other hazards that can lead to negative public
health effects, exposure, or environmental degradation.
(B) Areas with socioeconomic vulnerability.
(2) Of the 100 megawatts reserved pursuant to 2832(b)(1), they
shall be allocated as specified:
(A) Twenty percent shall be allocated to residential
customers.
(B) Projects shall be no larger than one megawatt.
(2) No less than 100 megawatts shall be reserved to the
residential class customers.
(3) Twenty megawatts shall be reserved for the City of Davis.
(c) To the extent possible, electrical corporations shall seek
to procure renewable energy supplies that are located within a
reasonable proximity to enrolled participants.
(d) Electrical corporations shall ensure that the program
supports diverse procurement and General Order 156 goals.
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(e) The tariff shall not allow a customer to subscribe to more
than 100 percent of the customer's load to the green tariff
shared renewable program.
(f) The tariff shall not allow a customer to subscribe to more
than two megawatts of generating capacity. This limitation
does not apply to a federal, state, or local government,
school or school district, county office of education, the
California Community Colleges, the California State
University, or the University of California. Electrical
corporations shall ensure that no single entity or its
affiliates or subsidiaries is awarded more than 20 percent of
any single calendar year's total cumulative rated generating
capacity made available pursuant to this program.
(j) To the extent possible, the electrical corporation shall
actively market the program to low-income and minority
communities and customers.
(h) Participating customers are to receive bill credits for
the generation using the class average retail generation rate
as established in the electrical corporation's approved tariff
for the class to which the participant belongs plus a
renewable adjustment value representing the difference between
the time of day profile of the renewable resource used to
serve the participant and the class average time of day
profile and the resource adequacy value, if any, of the
resource contained in this program.
(i) Participating customers shall pay a renewable power rate
established by the commission, the administrative costs of the
electrical corporation, and pay any other charges the
commission deems applicable to fully cover the cost of
procuring a green tariff shared renewable program's resources
to serve their needs.
(j) A participating customer's rates shall be debited or
credited with any other commission-approved costs or values
applicable to the renewable resources contained in this
program's portfolio. These additional costs or values shall be
applied to new customers when they initially subscribe after
the cost or value has been approved by the commission.
(k) Participating customers shall pay all otherwise applicable
charges without modification.
(l) Electrical corporations shall provide support for enhanced
community renewable programs to facilitate development of
renewable projects close to load.
(m) The commission shall ensure that charges and credits
associated with this program are set in a manner that ensures
nonparticipant ratepayer indifference for the remaining,
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bundled service, direct access, and community choice
aggregation customers and that no costs are shifted from
participating customers to nonparticipating ratepayers.
(n) Electrical corporations shall track and account for all
revenues and costs to ensure that the electrical corporation
recovers the actual costs of the program and that all costs
and revenues are fully transparent and auditable.
(o) Any renewable energy credits associated with power
procured by an electrical corporation for the green tariff
shared renewable energy program, and utilized by a green
tariff shared renewable energy program participant shall be
retired by the electrical corporation on behalf of the
participant. Those renewable energy credits shall not be
further sold, transferred, or otherwise monetized by a party
for any purpose. Any renewable energy credits associated with
power procured by an electrical corporation for the green
tariff shared renewable energy program, but not utilized by a
green tariff shared renewable energy program participant shall
be counted toward meeting that electrical corporation's
renewables portfolio standard. For the purposes of this
subdivision, the terms "renewable energy credit" and
"renewables portfolio standard" have the same meanings as
defined in Section 399.12.
(p) An electrical corporation shall, in the event of
participant attrition or related factors, apply the additional
resources procured through this program to the electrical
corporation's renewable portfolio standard procurement
obligations or banked for future use to benefit all customers
in accordance with renewable portfolio standard banking and
procurement rules.
(q) In calculating its procurement requirements to meet the
requirements of the California Renewables Portfolio Standard
Program (Article 16 (commencing with Section 399.11) of
Chapter 2.3 of Part 1), an electrical corporation may exclude
from total retail sales the kilowatthours generated by a
shared renewable energy facility and credited to a
participating customer, commencing with the point in time at
which the facility achieves commercial operation.
(r) All renewable energy procured on behalf of participants
will be compliance with the Air Resources Board Voluntary
Renewable Electricity Program. California-eligible greenhouse
gas allowances associated with these purchases must be retired
on behalf of participants as part of the Air Resources Board
Voluntary Renewable Electric Program.
(s) Electrical corporations shall provide municipalities with
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aggregated consumption data for participants within their
jurisdiction to allow for reporting on progress toward climate
action goals. Electrical corporations shall also publicly
disclose, on a geographic basis, consumption data and
greenhouse gas reductions achieved by participants, on an
aggregated basis consistent with privacy protections.
(t) This chapter shall remain in effect only until January 1,
2019, and as of that date is repealed, unless a later enacted
statute, that is enacted before January 1, 2019, deletes or
extends that date.
REGISTERED SUPPORT / OPPOSITION :
Support
All Power Labs
American Lung Association
Black Rock Solar
California Apartment Association (CAA)
California Environmental Justice Alliance
California Interfaith Power and Light
California League of Conservation Voters
California Native Plant Society (CNPS)
California Rural Legal Assistance Foundation
Cascade Hydro
City of Davis (sponsor)
Clean Power Campaign
CleanFocus Energy, Inc.
Cleanpath Ventures
CleanTECH San Diego
Coalition for Adequate School Housing (C.A.S.H.)
Community Environmental Council (CEC)
El Peco Energy, LLC
Energy and Financial Consulting LLC
Environment California
Environmental Health Coalition
Imani Energy, Inc.
Individuals in Support (14 letters)
League of California Cities
League of Women Voters of California
Los Angeles Business Council (LABC)
Mainstream Energy Corp.
Natel Energy Inc.
Navy Region Southwest
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Paula Perotte, Councilmember, City of Goleta
Redwood Coast Energy Authority
Ritual Coffee Roasters
School Energy Coalition (SEC)
Sierra Club California
Silicon Valley Leadership Group
Small Business California
Solar Energy Industry Association (SEIA) (if amended)
SolarCity
Sonoma County Board of Supervisors
SPP Energy Partners
SunEdison
Sungevity
Sunible
Sunrun
TerraVerde Renewable Partners
The Vote Solar Initiative (Vote Solar)
The Western Center on Law and Poverty
Tom Torlakson, State Superintendent of Public Instruction
UltraSystems Environmental
Yolo County Board of Supervisors
Opposition
California Farm Bureau Federation
Coalition of California Utility Employees
Independent Energy Producers (IEP) (unless amended)
Pacific Gas and Electric Company (PG&E)
San Diego Gas and Electric Company (SDG&E)
San Francisco Public Utilities Commission (SFPUC) (unless
amended)
Southern California Edison (SCE)
The Utility Reform Network (TURN) (unless amended)
Analysis Prepared by : Susan Kateley / U. & C. / (916)
319-2083