BILL ANALYSIS                                                                                                                                                                                                    Ó



          SENATE COMMITTEE ON ENVIRONMENTAL QUALITY
                               Senator Wieckowski, Chair
                                 2015 - 2016  Regular 
           
          Bill No:            AB 1530
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          |Author:    |Levine and Gordon                                    |
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          |Version:   |4/26/2016              |Hearing      |6/15/2016       |
          |           |                       |Date:        |                |
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          |Urgency:   |No                     |Fiscal:      |Yes             |
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          |Consultant:|Rebecca Newhouse                                     |
          |           |                                                     |
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          SUBJECT:  Electricity:  distributed generation.

            ANALYSIS:
          
          Existing law:  
          
          1) Establishes certain costs to be recovered from customers of  
             investor-owned utilities (IOUs) on a nonbypassable basis, such  
             as public purpose programs including rate assistance for  
             low-income customers, energy efficiency, and the Electric  
             Program Investment Charges (EPIC), bond repayments, and nuclear  
             decommission costs. 

          2) Provides incentives for self-generation.  (Public Utilities  
             Code §379.6)

          3) Requires retail sellers of electricity to increase purchases of  
             renewable energy such that at least 50% of retail sales are  
             procured from renewable energy resources by December 31, 2030.   
             (PUC §399.11 et seq.)

          4) Requires each IOU, by July 1, 2015, to submit to the California  
             Public Utilities Commission (CPUC) a distribution resources  
             plan proposal to identify optimal locations for the deployment  
             of distributed resources.  (PUC §769)

          5) Directs the California Air Resources Board (ARB) to adopt a  
             certification program and uniform emission standards for  
             electrical generation technologies, such as distributed  
             generation systems, that are exempt from local air district  







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             permitting requirements.  (Health and Safety Code §41514.9)

          This bill:  

          1) Establishes the category "clean distributed energy resource"  
             (clean DER) to mean a facility of 15 megawatts (MW) or less,  
             located on a customer's premises that generates electricity, or  
             electricity and useful heat, and sized to meet the customer's  
             onsite demand, and that meets, for each year of eligibility,  
             one of the following criteria: 

             a)    A greenhouse gas (GHG) emissions standard equivalent to,  
                or less than, 379 kilograms of CO2 equivalents per  
                megawatt-hour (kgCO2e/MWh) and complies with oxides of  
                nitrogen (NOx), carbon monoxide, and volatile organic  
                compound emissions standards adopted by ARB, as specified. 

             b)    Is a renewable energy resource under the RPS and will not  
                otherwise be addressed in the CPUC's implementation of the  
                distributed resource planning process or revision of the  
                rules regarding net energy metering. 

          2) Directs CPUC to require the three largest IOUs to:

             a)    Collect nonbypassable charges from any customer served by  
                clean DER based only on the actual metered consumption of  
                electricity delivered to the customer through the IOU's  
                transmission or distribution grid, and prohibits shifting of  
                costs to customers in a different customer class.

             b)    Adjust reserve capacity for standby service for clean DER  
                customers, as specified.

          3) Requires CPUC to suspend the eligibility of new customers to  
             receive the above rate program on December 31, 2020. 

          4) Requires the California Energy Resources Conservation and  
             Development Commission (CEC), in consultation with the CPUC, to  
             report on impacts of these provisions in the integrated energy  
             policy report filed on or before November 1, 2017, and November  
             1, 2019.  

           Background
          








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          1) Nonbypassable charges. Nonbypassable charges are fees that all  
             customers pay to recover fixed charges or program costs of the  
             IOU.  CPUC, pursuant to statute, authorizes IOUs to recover  
             certain fixed program costs from charges that are paid by all  
             customers in an IOU service territory, regardless of the source  
             of a given customer's electricity.  The largest component of  
             nonbypassable charges affected is the public purpose program  
             charge, which includes the California Alternative Rates for  
             Energy program (CARE), which funds state-mandated low-income  
             assistance, energy efficiency programs, and the electric  
             program investment charge (EPIC), that funds energy  
             technologies and research.  Smaller components are the  
             Department of Water Resources (DWR) bond charges, which  
             recovers the cost of bonds issued to finance power purchased by  
             DWR during the energy crisis, and nuclear decommissioning,  
             which provides for the funds required for site restoration when  
             the nuclear power plants are removed from service.  These  
             charges are volumetric, meaning they are based on the amount of  
             electricity used by the customer, usually expressed in dollar  
             per kilowatt-hour ($/KWh).

             Exemptions. Generally, a customer or customer group may be  
             granted an exemption from nonbypassable charges when the IOU  
             did not incur costs related to the particular category of  
             nonbypassable charge on behalf of that customer or customer  
             group. 

             Some customer generation is exempt from nonbypassable charges  
             through existing programs designed to encourage certain  
             customer behavior, such as adoption of renewable technology.   
             For example, customers who participate in the net  
             energy-metering program (NEM) pay electric utility  
             nonbypassable charges only on the electricity they receive from  
             the grid.  The NEM program allows a customer who installs small  
             solar, wind, biogas and fuel cell generation facilities (up to  
             1MW) that serve all or a portion of onsite generation needs, to  
             receive a financial credit for power generated by their onsite  
             system and fed back to the utility.  The credit is used to  
             offset the customer's electricity bill.  NEM eligibility (and  
             therefore exemption from nonbypassable charges) for fuel cells  
             using fossil natural gas expires at the end of this year. 

          2) Distributed generation. Distributed Generation (DG) generally  
             refers to smaller-scale electricity generation on-site or  








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             generation located closer to population centers or other high  
             demand areas.  DG can be produced with renewable or  
             non-renewable fuel sources; examples include small wind  
             turbines, rooftop solar, internal combustion engines, gas  
             turbines and fuel cells. 

             Traditional methods of electric generation and supply relies on  
             centralized electricity production from a few large-scale  
             generating stations located far from load centers, and  
             distributing that electricity through an extensive transmission  
             and distribution network.  Systems based on DG employ numerous,  
             small plants and can provide power onsite with little reliance  
             on the distribution and transmission grid.

             Renewable DG receives several types of incentives.  In addition  
             to bill credits for net electricity exported to the grid, NEM  
             customers are exempt from nonbypassable charges, as noted  
             above, and standby charges, costs associated with  
             interconnection application fees, studies and distribution  
             upgrades.

             DG also receives incentive payments through the California  
             Solar Initiative (limited to solar photovoltaic DG) and the  
             Self-Generation Incentive Program (SGIP). 

             Self-Generation Incentive Program.  SGIP was authorized by the  
             legislature in 2000, and established by the CPUC in 2001 to  
             reduce peak demand in response to the energy crisis.  The  
             program was modified by SB 412 (Kehoe, Chapter 182, Statutes of  
             2009) to include reduction of GHG emissions as a focus of the  
             program, in addition to other goals of the program, including  
             improving efficiency and reliability of the distribution and  
             transmission system, and reducing peak demand and ratepayer  
             costs.  SB 412 directed the CPUC, in consultation with ARB, to  
             identify distributed energy resources that contribute to  
             greenhouse gas reduction goals and to set appropriate incentive  
             levels to encourage their adoption.  Pursuant to SB 412, CPUC  
             set the GHG emissions level for eligible DG in 2011 at or below  
             379 kgCO2e/MWh.  This value was based on the AB 32 Scoping Plan  
             estimate of the average emissions of natural gas  
             fired-electricity generation from 2002 to 2004 and adjusted  
             downward by CPUC by 20% to account for the RPS (which has since  
             increased to a 33% renewable energy procurement requirement by  
             2020, and a 50% procurement mandate by 2050), and adjusted for  








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             avoided line losses. 

             DG technologies provided incentives under SGIP include  
             renewable technologies, such as wind and biogas-fueled  
             generation, and non-renewable, natural gas-fueled electricity  
             generation, including combined heat and power (CHP) fuel cells,  
             electric-only fuel cells, gas turbines, internal combustion  
             engines, and microturbines.  CHP refers to the production of  
             electricity and heat from a single fuel source and increases  
             efficiencies of systems that run on natural gas by capturing  
             waste heat for conversion of useful thermal energy. 

             SB 861 (Budget and Fiscal Review Committee, Chapter 35,  
             Statutes of 2014) extended SGIP until 2021 and required CPUC to  
             update, by July 2015, the GHG emissions factor for avoided GHG  
             emissions based on ARB's most recent data on GHG emissions from  
             electricity sales in IOU service areas and estimates of GHG  
             emissions over the useful life of the distributed generation  
             technology. 

             In November of 2015, CPUC lowered the GHG emissions ceiling for  
             DG eligible for SGIP incentives to a 10-year average emissions  
             rate of 350 kgCO2e/MWh.

             Since the start of the program, about $3.7 billion has been  
             allocated for incentive payments to renewable and non-renewable  
             DG.  This year, over $77 million is authorized for SGIP  
             incentives to eligible DG resources.

          3) Emissions impacts of distributed generation.  The electricity  
             sector and environmental impacts of DG are dependent on where  
             the distributed generation is deployed in relation to the  
             distribution system, how the technology operates (e.g.,  
             intermittent or baseload resource) and, for non-renewable  
             technologies, the efficiency, type of fuel, and emissions  
             specifications of DG compared to the characteristics of the  
             electricity the distributed generation is displacing.  As all  
             these factors may vary greatly, estimating potential  
             environmental impacts and benefits of this type of electrical  
             generation is not a straightforward analysis. 


             For the SGIP program, CPUC contracts with a third-party  
             consulting firm, Itron, to perform annual impact evaluations of  








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             the program to quantify the energy, demand, and environmental  
             impacts.  The report calculates emission impacts of the  
             technologies under SGIP as the difference between the emissions  
             generated by SGIP systems and baseline emissions that would  
             have occurred in the absence of the program. 


             The April 2015 Itron Report assessed SGIP impacts from the  
             beginning of the program until 2013, and found that after 2011  
             (at which point GHG emissions reductions became a goal of the  
             program), there was a shift from a net increase in GHG  
             emissions from non-renewable DG under the program, to a  
             marginal net reduction in net GHG emissions in 2012, and  
             increased GHG emissions reductions in 2013 (a GHG emissions  
             reduction of 12,000 metric tons CO2e/MWh).  These non-renewable  
             SGIP projects include CHP fuel cells, electric-only fuel cells,  
             gas turbines, internal combustion engines, and microturbines,  
             operating on natural gas. 


             For comparison, renewable SGIP resources (wind and  
             biogas-fueled DG) in 2013 were estimated to result in net GHG  
             reductions of 150,000 metric tons of CO2e/MWh (3.5 times more  
             GHG emission reductions than the non-renewable SGIP projects).


             As expected, GHG emissions reductions vary substantially for  
             different non-renewable distributed generation technologies.   
             According to the report (which assigns a net GHG emissions  
             reductions a negative "GHG impact" score), "CHP fuel cells and  
             gas turbines have a higher emissions rate than the electrical  
             power plants that they avoid...but are able to overcome this  
             deficit by recovering useful heat for heating... and  
             cooling...services.  The result is a negative emissions  
             impact...relative to the conventional energy services baseline.  
              Electric-only fuel cells do not recover useful heat but have a  
             lower emissions rate than the electric power plants they  
             avoid.... Internal combustion engines and microturbines had  
             high emissions rates and did not recover sufficient useful heat  
             to achieve negative GHG impacts."


             Criteria air pollutant reductions.  Like GHG emissions,  
             criteria air pollutant emissions are proportional to the amount  








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             of fuel consumed for a specific technology.  Depending on the  
             type of technology, criteria air pollutant emissions from DG  
             can vary greatly.  For example, diesel generators (not included  
             under SGIP or this bill) are one of the dirtier forms of  
             distributed generation and have some of the most significant  
             emissions of toxic and criteria air pollutants compared to  
             other types of electricity generation.  In contrast, fuel  
             cells, which do not use a combustion process, have one of the  
             lowest emissions levels of NOx and PM10 emissions for  
             non-renewable electrical generation. 


             According to the April 2015 Impact Evaluation report, for  
             non-renewable SGIP distributed generation, "All technologies  
             supplied with non-renewable fuel decreased NOx and PM10  
             emissions. SO2 emissions from technologies supplied with  
             non-renewable fuel were marginal.  These results indicate that  
             non- renewable SGIP technologies with high electrical  
             efficiencies and low air pollutant emissions (e.g., fuel cells)  
             generate fewer emissions than the conventional energy services  
             baseline. In addition, SGIP technologies with lower electrical  
             efficiencies but which recovered useful waste heat reduce  
             criteria air pollutants overall." 


             The report also notes, "The 2013 impacts evaluation marks the  
             first attempt at quantifying the NOx, PM10, and SO2 impacts of  
             the SGIP.  While the analysis methodology presented here is  
             sound, there is room for improvement. Emissions data from the  
             California Air Resources Board and local air quality municipal  
             districts should be leveraged to obtain more accurate estimates  
             of emissions rates from distributed energy resources and  
             boilers."


          4) Local air district permitting and ARB certification. Air  
             permitting requirements for DG vary throughout California due  
             to regional differences in air quality and also depend on the  
             type of DG technology.  Air districts in regions designated as  
             non-attainment under the federal and state Clean Air Acts may  
             require distributed generation projects to install  
             best-available control technology and to offset their emission  
             of criteria pollutants.  However, local air districts do not  
             require air permits for DG that does not emit air pollution or  








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             whose emissions are below air district permitting thresholds,  
             which vary depending on the air district. 


             To address regulatory gaps in local air district permitting of  
             DG, SB 1298 (Bowen and Peace, Chapter 741, Statutes of 2000)  
             directed ARB to develop an air pollution control certification  
             program for distributed generation technologies that are exempt  
             from local air permitting requirements by January 2003 and  
             requires that those standards reflect the best performance  
             achieved in practice by existing electrical generation  
             technologies.  The current regulation, amended in 2006,  
             requires all DG running on fossil fuel to meet emissions  
             standards for NOx, carbon monoxide, and volatile organic  
             compounds (VOCs).  The NOx standard is set at 0.07 lbs/MWh,  
             approximately equivalent to a NOx emissions factor for a new,  
             central-station baseload natural gas powerplant. 


            


          Comments
          
          1) Purpose of Bill.  According to the author, "Clean onsite  
             distributed energy resources allow for cleaner, lower cost,  
             more reliable energy generation. On-site distributed generation  
             technologies offer a clean energy choice that provides air  
             quality benefits by reducing emissions of high criteria air  
             pollutants and greenhouse gases.  Clean DG reduces the need for  
             energy generation that emits higher levels of greenhouse gases  
             that contribute to climate change and higher levels of criteria  
             air pollutants that contribute to smog formation.  These  
             technologies are primed to help California reach its clean  
             energy goals.  They are part of the solution, and are ready to  
             be deployed now to meet the state's growing demand while  
             providing critical environmental, economic and social  
             benefits."

          2) Emissions impacts of non-renewable distributed generation.  The  
             environmental benefits of DG depend on a variety of factors,  
             including technology, fuel type, as well as where and when the  
             technology is dispatched. For zero-emission distributed  
             generation, the analysis of GHG emissions and criteria air  








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             pollutant benefits is more straightforward.  For the most part,  
             any grid electricity displaced by these resources results in  
             avoided GHG emissions and criteria air pollutants. 

             For non-renewable DG, the emissions impact depends on the  
             emissions rate of the technology, and the type of generation  
             the DG is displacing. In the short-term, this analysis of  
             avoided GHG emissions looks at avoided resources on the margin  
             that would have otherwise needed to operate to meet electricity  
             needs.  According to the CPUC, this short-term "operating  
             margin effect" for displaced energy is likely some fraction of  
             existing combined cycle natural gas power plants (with an  
             average emissions factor of 382 kgCO2e/MWh) and simple cycle  
             combustion turbines (also known as peaker plants, with average  
             emissions of 544 kgCO2/MWh ).

             In the long-term, the emissions impact of distributed  
             generation would depend on the avoided resources that would  
             otherwise need to be built to meet electricity needs.  In  
             general, due to the RPS requirement, these avoided resources  
             will likely be some increasing fraction of renewable resources  
             as well as newer, more efficient natural gas generation.   
             Because of various scenarios, and the different types of  
             non-renewable technologies, there is uncertainty in terms of  
             the extent of avoided emissions with non-renewable DG.

             Although the average emissions intensity of the electrical grid  
             is not necessarily representative of the energy displaced by  
             distributed generation, it is notable that PG&E and Southern  
             California Edison have grid emissions intensities of 179 and  
             259 kgCO2e/MWh-both significantly lower than the emissions  
             limit in AB 1530 (379 kgCO2e/MWh). 

          3) Static GHG emissions standard based on outdated assumptions.   
             AB 1530 defines distributed generation at or below a GHG  
             emissions intensity of 379 kgCO2e/MWh as a "clean distributed  
             energy resource" and exempts this type of generation from  
             nonbypassable charges.  According to the CPUC, the original  
             SGIP standard of 379 kgCO2e/MWh established in 2011was based on  
             average natural gas power plant emissions from 2002 to 2004 and  
             adjusted downward by 20% to account for the RPS.  The average  
             power plants emissions data used to generate the emissions  
             factor that currently establishes eligibility for clean DER in  
             this bill is now over a decade old, and does not reflect the  








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             lower emission rate of newer, more modern gas-fired generation.  
              Additionally, by 2014, the three largest IOUs had all procured  
             over 20% of their RPS requirement (with San Diego Gas &  
             Electric over 36%).  As this standard is not based on current  
             data, it appears to be somewhat arbitrary, and therefore does  
             not ensure qualifying distributed generation is "clean." 

             Additionally, although the bill sunsets eligibility for new DG  
             to qualify for nonbypassable charge exemption under this bill,  
             DG meeting the definition of clean DER and installed before  
             December 31, 2020 (unless the sunset is extended or repealed),  
             will be exempt from paying the nonbypassable charges for the  
             entire useful life of the technology, which could be 10 to 20  
             years from now.  At that point, the grid will likely be  
             substantially cleaner. However, under this bill incentives will  
             continue to be provided to what will effectively look like  
             dirty generation relative to a grid made up of 50% or greater  
             renewable energy resources. 

          4) More than a reauthorization.  Proponents of AB 1530 argue that  
                                                                              the bill extends the "no use, no fee" policy that NEM  
             customers, including fuel cells using natural gas, qualify for.  
              Under the NEM tariff, DG customers only pay nonbypassable  
             charges on electricity they receive from an IOU.  NEM was  
             recently extended for renewable DG (without the 1MW cap), but  
             the eligibility for fossil natural gas fuel cell distributed  
             generation sunsets at the end of this year.  However, there are  
             several notable differences between AB 1530 and a  
             reauthorization of the nonbypassable charges exemption.   
             Whereas the NEM policy limits non-renewable customer  
             participation to natural gas fuel cells (until the end of  
             2016), under AB 1530, fuel cells, as well as other  
             non-renewable DG technologies including gas turbines, internal  
             combustion engines, and microturbines, may qualify.   
             Additionally, the exemption from nonbypassable charges would  
             apply for generation up to fifteen times the current  
             eligibility limit for NEM fuel cell customers.  This is a  
             significant expansion (1MW can power 600 to 700 homes, whereas  
             15MW can power around 10,000 homes).

          5) RPS.  Under the RPS, load-serving entities, including IOUs, are  
             required to meet 50% of their load from renewable energy  
             resources by December 31, 2030.  Customer generation, itself  
             exempt from RPS requirements, decreases the load of the  








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             load-serving entity, and ultimately reduces the renewable  
             resource generation IOUs need to procure to meet the 50% RPS  
             requirement.  To the extent the exemption from nonbypassable  
             charges results in a large number of customers that install  
             clean DER at or near the 15MW limit, the corresponding  
             reduction in electrical load may significantly reduce renewable  
             energy procurement by IOUs.

          6) Commitments to natural gas.  This bill captures both renewable  
             and non-renewable "clean distributed energy resources," but  
             because renewable distributed generation can take advantage of  
             other, potentially more generous incentives, the primary  
             beneficiaries of this bill would be non-renewable technologies  
             using fossil natural gas. 

             Methane (CH4) is the principal component of natural gas.   
             Methane is 84 times more powerful as a global warming pollutant  
             than CO2 on a 20-year time scale. Atmospheric methane  
             concentrations have been increasing as a result of human  
             activities related to agriculture, fossil fuel extraction and  
             distribution, and waste generation and processing.

             A growing body of evidence suggests that national and state  
             estimates of methane emissions from the natural gas sector have  
             been significantly underestimated.  Studies suggest that U.S.  
             methane emissions from all sources are likely anywhere from 25  
             to 75% higher than EPA estimates, and they note the discrepancy  
             may in large part be due to a small number of very large leaks  
             from the natural gas production and distribution system.

             Additionally, several recent analyses of atmospheric  
             measurements in state suggest that actual California methane  
             emissions may be 30 to 70% higher than estimated in ARB's  
             emission inventory.  The Short-Lived Climate Pollutant draft  
             strategy notes that several efforts are underway at the CEC and  
             ARB to improve emissions monitoring to help identify sources of  
             fugitive methane emissions and reduce them, including from oil  
             and gas operations.  Although the state has worked to reduce  
             fugitive methane emissions from various sources over recent  
             years, including new efforts to reduce fugitive leaks from  
             natural gas infrastructure in the state, 91% of the natural gas  
             used in California is imported.  










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             Providing incentives for distributed technologies requiring  
             long-term natural gas contracts, although potentially more  
             efficient than centralized natural gas powerplants, may run  
             contrary to the RPS, and other policies, that are working to  
             decarbonize the state's electricity sector and meet ambitious  
             climate goals.


          7) Amendment.  As the bill was originally amended to address the  
             issue of clean DER and nonbypassable charges at the end of last  
             year, the dates in the bill determining the applicability of  
             the nonbypassable and standby charge requirements in the bill  
             for new clean DER customers should be pushed out a year.  For  
             example, the bill currently appears to operate retroactively,  
             with the new nonbypassable and standby charge requirements of  
             this bill applying to clean DER installed after January 1,  
             2016.

            Related/Prior Legislation
          
            AB 674 (Mullin, 2015) contained similar provisions to AB 1530.  AB  
          674 was held on the Assembly Appropriations suspense file. 
           
           AB 2441 (Mullin, 2014) was similar to AB 1530. The bill was held  
          in the Senate Rules Committee. 

          AB 2649 (Mullin, 2014) was similar to AB 1530, but was amended to  
          a different subject matter and held on the Senate Appropriations  
          Committee Suspense file. 

          AB 365 (Mullin, 2013) contained similar provisions to AB 1530. The  
          bill was held in the Senate Rules Committee. 

            DOUBLE REFERRAL:  
          
          This measure was heard in Senate Energy, Utilities and  
          Communications Committee on April 19, 2016, and passed out of  
          committee with a vote of 6-4.
           
           SOURCE:               TechNet  

           SUPPORT:               

          Association of California Water Agencies








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          Bloom Energy
          Capstone
          Caterpiller
          DE Solutions
          Doosan Fuel Cell America
          EtaGen
          LG 
          National Fuel Cell Research Center
          NLine Energy, Inc.  
           Sierra Nevada Brewing Company
          Silicon Valley Leadership Group
          Solar Turbines
          Tecogen
            
          OPPOSITION:    

          California State Association of Electrical Workers
          California State Pipe Trades Council 
          California Manufacturers and Technology Association
          Coalition of California Utility Employees
          Natural Resources Defense Council
          Pacific Gas and Electric Company
          San Diego Gas and Electric Company
          San Francisco Public Utilities Commission
          Sierra Club California
          Southern California Edison
          The Utility Reform Network  
           Western States Council of Sheet Metal Workers
           
           ARGUMENTS IN  
          SUPPORT:    Supporters state that AB 1530 extends existing 
          state law that expires at the end of this year that protects  
                         customers from having to
          pay utility fees assessed on clean energy generated onsite by the  
                         customer. 
          Supporters note that without AB 1530, customers who choose to  
                         invest their own
          capital to install clean, onsite electricity generation  
                         technologies will have to pay a
          number of utility-imposed fees on electricity they generate and  
                         consume on-site. 
          They add that these charges would create an economic disincentive  
                         for customers
          to deploy new, innovative and clean technologies that will benefit  








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                         all Californians.
          Supporters also state that on-site distributed generation  
                         technologies offer a clean
          energy choice that provides air quality benefits by reducing  
                         emissions of high
          criteria air pollutants and GHGs, and that clean DG reduces the  
                         need for energy 
          generation that emits higher levels of GHGs that contribute to  
                         climate change and
          smog formation. 
           
           ARGUMENTS IN  
          OPPOSITION:    Opponents say that AB 1530 creates
          exemptions from nonbypassable charges, including those established  
                         to ensure 
          customers pay their fair share for public purpose programs such as  
                         low-income
          ratepayer assistance, and energy efficiency, for customers who  
                         install non-
          renewable, fossil fuel self-generation.  The opponents argue that  
                         these exemptions 
          would result in an unfair cost shift from participating customers  
                         to non
          -participating customers. Southern California Edison states the  
                         reliability,
          infrastructure, and other ratepayer benefits purposed by the  
                         bill's proponents are
          questionable, and even if actualized, have no nexus to the  
                         exemptions being
          sought. The California State Association of Electrical Workers,  
                         Coalition of
          California Utility Employees, California State Pipe Trades Council  
                         and Western 
          States Council of Sheet Metal Workers also argue that AB 1530 not  
                         only conflicts
          with the state's energy policy of the last 15 years, which has  
                         been focused on
          reducing reliance on fossil fuels, but is directly contrary to the  
          50% RPS 
          requirement and SB 350 (de León).  The Natural Resources Defense  
          Council opposes the bill, unless the bill is amended to reinstate  
          a prior provision of the bill which required the emissions  
          threshold to ratchet down over time, pursuant to the appropriate  
          determination by the ARB.








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          ?
          
          
          
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