BILL ANALYSIS 1
1
SENATE ENERGY, UTILITIES AND COMMUNICATIONS COMMITTEE
ALEX PADILLA, CHAIR
AB 64 - Krekorian/Bass Hearing Date:
June 30, 2009 A
As Amended: June 23, 2009 FISCAL B
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DESCRIPTION
33% RPS
Current law requires investor-owned utilities (IOUs) and energy
service providers (ESPs) (also defined as retail sellers) to
increase their existing purchases of renewable energy by 1
percent of sales per year such that 20 percent of their retail
sales, as measured by usage, are procured from eligible renewable
resources by December 31, 2010. This is known as the Renewable
Portfolio Standard (RPS).
Current law exempts publicly owned utilities (POUs) from the RPS
program and instead requires these utilities to implement and
enforce their own renewable energy purchase programs that
recognize the intent of the Legislature to encourage increasing
use of renewable resources.
This bill requires IOUs, POUs and ESPs to increase purchases of
renewable energy such that at least 23 percent of electricity
delivered to retail customers is from a renewable energy resource
by 2014; 27 percent by 2017; and 33 percent by 2020. IOUs and
ESPs would still be required to meet the 20 percent by 2010
mandate. A new firm requirement of 20 percent by 2010 would be
required of the POUs.
This bill generally requires that the IOUs follow existing
planning, procurement, and cost containment laws (PUC Sections
399.11 et seq) until each IOU reaches its 20 percent RPS goal, at
which time new provisions would trigger (proposed PUC Sections
950 et seq).
Cost Containment
Current law requires the CPUC to develop, by rulemaking, a
procurement process for renewable resources by IOUs which
includes the determination of a benchmark for the market price
(market price referent or MPR) of electric generation against
which renewable contracts are evaluated for reasonableness in
price. If the generation costs of those contracts exceed the MPR
those costs are collectively measured against specified
thresholds which if exceeded relieve the IOU's of contracting for
additional renewable generation at costs above the MPR (aka cost
cap).
This bill modifies the calculation of the MPR, now cast as the
"benchmark price," to also include the value of reducing
emissions of greenhouses gases and the value of increasing the
diversity of electricity generation. This bill prohibits the
CPUC from presuming an RPS contract is reasonable if its cost is
less than the benchmark price and is the sole basis for
determining whether a contract is just and reasonable.
This bill suspends a retail seller's obligation to procure
renewable resources if the costs of contracts above the benchmark
price collectively exceed 5 percent of the retail sellers "total
system annual revenue requirements." Procurement above benchmark
prices could continue at the option the retail seller subject to
CPUC approval.
Delivery/RECs
Current law requires renewable resources to be generated in, or
delivered to, the California grid.
This bill defines delivery and delivered to mean that electricity
from a renewable resource is used to serve California customers
or is simultaneously scheduled to meet anticipated in-state load.
Current law defines electric generation resources that are
eligible to be counted toward the 20 percent RPS mandate.
This bill defines an eligible renewable resource to include an
unlimited number of renewable energy credits for resources if
procured prior to January 1, 2010 and were previously determined
as eligible by the California Energy Commission (CEC).
Enforcement
Current law requires the CPUC to assess penalties on a retail
seller which fails to reach its RPS obligations but allows waiver
of the penalties under certain conditions.
This bill permits the CPUC to waive compliance penalties if it
determines that the retail seller has made a reasonable effort to
meets its RPS obligations or has made investments in energy
efficiency that have resulted in significantly less demand for
electricity.
Miscellaneous
This bill directs the CPUC to provide a preference to contracts
for eligible renewable resources for California Suppliers.
This bill requires the CPUC to report to the Legislature every
two years on the status and progress of achieving the 33 percent
RPS.
This bill directs the CEC to implement the RPS law so that it is
compatible with and does not preclude the installation of 4,000
MW electrical generation from combined heat and power systems
POUs
This bill requires POUs to adopt a program to procure 33 percent
of retail electric sales from renewable resources and to disclose
to the public and the CEC when it will deliberate its RPS
procurement plan, its status and further plans under specified
timelines and with specified details. An additional annual
report is required to its customers and the CEC on the
expenditures, resource mix and progress toward meeting the RPS.
This bill suspends the requirement of a POU to procure additional
renewable resources in any 3-year period that the POU's costs
exceed its total system annual revenue requirements.
This bill exempts the Trinity Public Utility District from
compliance with the RPS and makes specific accommodations for the
Truckee Donner Public Utility District.
This bill directs the CEC, if it determines that a POU has failed
to comply with the RPS, to refer a POU to the California Air
Resources Board (CARB) so that it may impose penalties for
failure to comply.
Transmission/Siting
This bill creates the Energy Planning and Infrastructure
Coordinating Committee (EPIC) comprised of the President of the
CPUC, Chair of the CEC, Secretaries of the Environmental
Protection and Resources agencies, and Chair of the Independent
System Operator (ISO) as voting members and other specified
nonvoting members. Its charge would be to develop a strategic
plan to meet the RPS goals of the bill.
Current law charges the CEC with siting authority for all thermal
power plants with a capacity of 50 megawatts (MW) or more.
This bill expands the authority of the CEC to site renewable
energy resource plants of 5 MW or more which would include wind,
solar technologies, geothermal, biomass, and others.
Current law requires a certificate of public convenience and
necessity (CPCN) from the CPUC to construct a transmission line.
This bill requires the CPUC to approve an application for a CPCN
for a line that will facilitate the transmission of renewable
generation within one year of the filing of a completed CPCN.
The CPUC could also accept a determination of need from the ISO
as a rebuttable presumption with concurrence by the Division of
Ratepayer Advocates.
BACKGROUND
In 2002 legislation was enacted to require the IOUs (e.g. Pacific
Gas & Electric, Southern California Edison, San Diego Gas and
Electric Company) and the private companies that compete with the
utilities to increase their annual purchases of electricity from
renewable resources by at least 1 percent so that 20 percent of
their sales would come from renewable sources by 2017. In 2006
legislation was enacted to accelerate the 20 percent requirement
to the end of 2010 (SB 107, Simitian).
The RPS program does not require renewable energy purchases
irrespective of cost. Each contract for the development and
purchase of renewable energy is submitted to the CPUC for review.
Any contract below the market price is deemed per se reasonable.
Any contract above the market price is submitted to a
procurement review group to consider the reasonableness of costs.
To address the overall costs of the RPS, an above-market cost
cap was determined for each IOU. If the IOUs costs reach that
cap in any given year, then the requirement for additional
renewable energy purchases at above-market costs is waived.
However, an IOU can still, voluntarily, propose to procure
renewable resources at above-market prices outside of the cost
cap (referred to as bi-lateral contracts) which calls into
question whether a cost cap really exists. The cost cap has not
been triggered and the IOUs continue to pursue renewable
contracts to meet the 2010 goal.
Since the initial adoption of the RPS program, the necessity of
bringing more renewable resources to the grid has been heightened
as a result of the mandate that the state reduce its greenhouse
gas (GHG) emissions to 1990 levels by 2020. In fact the CARB
scoping plan adopts a statewide 33 percent by 2020 renewable
energy mix in order to achieve the GHG goals.
Progress toward 2010 goal - The CPUC reports that, for 2007, the
IOUs have achieved varying levels of progress toward the 20
percent goal: PG&E - 11.4%; SCE - 15.7%; SDG&E - 5.2%. The
numbers actually declined from 2006 due primarily to load growth.
All agencies and stakeholders agree that the IOUs will not meet
the 2010 deadline. However, the CPUC reported in October, 2008
that an evaluation of the IOUs progress, including generation
developed and contracted for, would result in compliance in or
around 2013.
How much do we need? - The CPUC also reported that 31,000
gigawatt hours (GWh) of renewable generation is in existence
today. An additional 29,000 GWh is necessary to reach the 20
percent RPS goal for a total of 60,000 GWh. To reach 33 percent
an additional 41,000 GWh would be needed for a total of 101,000
GWh. Is it available? Yes. The Phase 1B Report of the Regional
Energy Transmission Initiative indicates that more than 208,000
GWh of "cost-effective large scale" renewable resources are
available in concentrated areas (identified as Competitive
Renewable Energy Zones [CREZ]) within the State of California and
immediately adjacent areas in bordering states, thus identifying
resource areas to bring renewable resources far in excess of
California needs.
Implementation of RPS - This month the CPUC released preliminary
results on analyzing the feasibility and costs of advancing the
RPS targets from 20 percent to 33 percent by 2020. According to
the report, "achieving 33% RPS by the year 2020 is highly
ambitious, given the magnitude of the infrastructure buildout
required." The report also looked at the costs of achieving a 33
percent RPS. Under the CPUC's analysis, the incremental cost of
moving from the current 20 percent RPS mandate to a 33 percent
RPS would result in a 7.1 percent increase in utility costs. The
increased cost include the costs of more expensive generation
resources, new transmission, and other resources that will be
needed to provide back up generation when renewable electricity
is not available. The cost increases assumes the utility will
continue the same balance of renewable technologies that they are
perusing today, which includes a large reliance on wind and solar
energy. The cost increases also assume the direct costs of
building new renewable facilities remains unchanged over time and
do not take into account potential decreases in technology costs
overtime.
Siting New Generation - It is important to recognize that the
scale of renewable development being pursued by California is
unprecedented. It is more aggressive than any other state in the
union and perhaps the world. To put this into context, the
committee is aware of only two significantly sized, concentrated
solar thermal energy sources in the country - Southern California
Edison's 640 MW SEGS units which came on line in the late 1980s
and the Nevada Solar One unit near Boulder City, Nevada at 64 MW
which came on line in 2007. The CEC now has six solar thermal
projects in permitting totaling more than 2,500 MW and impacting
more than 21,000 acres of land. The CEC is in uncharted
territory. The demands of staff, careful agency coordination
(e.g. State Department of Fish & Game, Federal Bureau of Land
Management, and Department of Defense), CEQA implications and
other planning challenges are only just now coming to the fore.
The RETI - The Renewable Energy Transmission Initiative (RETI) is
a statewide initiative to help identify the transmission projects
needed to accommodate these renewable energy goals, support
future energy policy, and facilitate transmission corridor
designation and transmission and generation siting and
permitting. RETI is intended to be an open and transparent
collaborative process in which all interested parties are
encouraged to participate.
RETI has assessed all competitive renewable energy zones in
California and some in neighboring states that can provide
significant electricity to California consumers by the year 2020.
RETI has also identified those zones that can be developed in the
most cost effective and environmentally benign manner and will
prepare detailed transmission plans for those zones identified
for development.
The RETI effort is supervised by a coordinating committee
comprised of California entities responsible for ensuring the
implementation of the state's renewable energy policies and
development of electric infrastructure, namely:
California Public Utilities Commission
California Energy Commission
California Independent System Operator
Publicly-Owned Utilities (SCPPA, SMUD, and NCPA)
Transmission Progress - Three new transmission lines have been
approved for California or are nearing approval - Tehachapi,
Sunrise, Devers-Palo Verde 2. The CPUC's October 2008 RPS status
report indicates that two new transmission lines are necessary to
meet the 20 percent goal. An additional five lines would be
needed to achieve 33 percent by 2020.
COMMENTS
1. Cost Containment (IOUs) - The current above above-market
cost of renewable electricity is determined by the CPUC
based on forecasts of the estimated cost of running a
natural gas fired power plant plus the cost of carbon
emissions from a natural gas facility. The market price is
referred to as the market price referent (MPR) and it allows
the cost of an RPS contract to be measured against the MPR
to show the incremental costs of renewable resources also
referred to as the above market costs.
This bill eliminates the MPR and directs the CPUC to develop
a "benchmark price" for renewable generation based on
specified elements, none of which relate to the costs of a
new natural gas plant, and all of which relate to the price
of fixed contracts in existence for renewable generation.
The benchmark price proposed in this bill is not used to
measure the reasonableness of an RPS contract and in fact is
prohibited.
If cost containment is the goal, then the problem with the
new benchmark price is that it effectively establishes a
green rate for new RPS contracts and eliminates any
connection between the market costs of new traditional
generation and new renewable generation instead comparing
the price of renewable contracts previously consummated, but
not necessarily online, and a new renewable contract.
Under this structure, if the cost of an RPS contract comes
in higher than the benchmark price then the difference
between the two is counted as an "above-market cost." The
above market costs are aggregated and when those costs reach
more than five percent of the annual revenue requirement
(which is defined) of an IOU, the obligation to procure
renewable electricity is suspended. It is not clear by the
terms of the bill whether the cost cap is an annual amount
or a one-time calculation meant to last until the 33 percent
target is reached.
The result is not the tracking of true above market costs
but the tracking of the increase in renewable contracts over
time. Given that the benchmark price is a green rate, the
effectiveness of a cost cap seems to be minimal and more
like a continual growth allowance for renewable contracts
from year to year. Additionally the benchmark price could
stymie competition among renewable resources. The IOUs
primarily rely on competitive solicitations for renewable
procurement. Bidders are aware of last year's MPR but not
the current year MPR calculation. Nevertheless bidders know
that their RPS proposals will be measured against the MPR
which acts as a tether on RPS prices. Anecdotal reports
indicate that RPS solicitations come in below, at, and above
the MPR. Replacing the MPR with a green benchmark price may
drive the costs of renewable contracts up as bidders realize
that see a much higher benchmark price for renewables.
2. Cost Containment - ESPs & POUs - This author attempts to
put into place a cost cap for POUs and ESPs to limit the
costs of renewable procurement. However, the defined cap
uses calculations that are unique to IOUs regulated by the
CPUC and have no relation to ESPs. Under this provision
contracting by ESPs may also be subject to some level of
regulation by the CPUC which would not be appropriate. It
is not clear to the committee at this time whether POUs have
a revenue requirement. The effort to afford these parties
with a cost cap just as there is for IOUs is warranted but
should be clarified.
3. Delivery - To count toward a retail seller's RPS
obligation, a renewable facility must meet several
requirements including that the facility be located in
California or deliver its electricity to California. The
definition of "deliver" in current law was written to allow
an out-of-state renewable generator that wants to serve
California load to comply with ISO rules that require
out-of-state electricity to be scheduled into California at
specific times and amounts. Since renewable resources like
wind and solar are intermittent, they cannot be scheduled at
specific times and amounts. The intent of the language was
for the renewable energy to come to California at some point
and then offset the need for fossil fuel generation within
California. However, the CEC, which sets the eligibility
rules, interpreted the statutory language to allow for
transactions where the renewable electricity never comes to
California to count toward the RPS as an eligible resource.
It appears that the author intended to address this issue by
restricting the delivery requirement to that which is
simultaneous with the generation of the renewable
electricity but this is not clear. Additionally, the
trigger date for the new delivery requirement is not clear
(see comment 6 below.) In the meantime the author has also
repealed the current delivery requirement in Public
Resources Code Section 25741 but left in tact all other
current RPS program rules until retail sellers reach the 20
percent RPS goal. It appears that there is no delivery
requirement in effect until at least January 1, 2011 and
perhaps not until each retail seller reaches the 20 percent
goal leaving the delivery requirement for RPS generation in
limbo.
4. Renewable Energy Credits and Deliverability - A Renewable
Energy Credit (REC) generally represents the environmental
and renewable attributes of renewable electricity as a
separate commodity from the energy itself. In concept and
under current law, a REC can be sold either "bundled" with
the underlying energy or "unbundled" into a separate REC
trading market.<1> In general, RECs can be traded in
voluntary markets or compliance markets. In the voluntary
market, any company (e.g. a grocery store chain) that wishes
to claim that it is powered by clean energy may buy
non-renewable power from its local energy provider and also
buy an equivalent amount of RECs that have been "unbundled"
from renewable energy produced elsewhere. In some RPS
compliance markets, the load serving entities can use
unbundled RECs, rather than actual renewable energy, to
comply with their RPS goals. In either case, once the RECs
are unbundled from the energy, the energy is considered
non-renewable power.
In the Western region of the U.S., RECs (both voluntary and
compliance) are tracked using the Western Renewable Energy
Generation Information System (WREGIS) as called for under
current law. WREGIS was launched in mid-2007.
The author of the legislation which permitted the trading of
RECs has stated that the intent was to only allow the
trading of RECs - bundled or unbundled - within the state.
However, an attenuated interpretation of the definition of
"delivered" under current law by the CEC (see comment 3
above), has resulted in contracts for renewable generation
from as far away as Montana. This out of state generation
can never be physically delivered to the California grid
because of its remote location and the fact that the ISO has
no ability to monitor, control or schedule the generation.
The consequence is that the renewable resource would be
generated out of state at one time and sold to a third
party, not delivered to California and might be referred to
as a bait and switch. The third party would later deliver
"system power" to the California grid when scheduled by the
IOU and ISO. In its review of this practice The Utility
Reform Network (TURN) notes "since a significant amount of
firm imports into California are from coal plants, it is now
likely that utilities and load serving entities will be
getting RPS credit for importing coal power." Coal
contracts of greater than five years duration are prohibited
under state law. System power contracts are not prohibited.
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<1> The CPUC has not issued a final rulemaking for the use of
RECs. Consequently they are authorized under state law but the
trading process is not yet available to IOUs or ESPs.
Additionally, a pending rulemaking by the CPUC couples the
CEC's attenuated definition of "delivery" with the REC
authority resulting in a pending decision to permit the
trading of unlimited RECs to achieve RPS compliance from
anywhere in the WECC.<2>
This bill does not authorize the use of unbundled RECs but
it does reference them. This bill allows RECs but does not
clearly or definitively address the delivery issue (see
comment 3 above). Consequently, the ability of an IOU, POU,
or ESP to use RECs from in-state or out-of-state renewable
resources is not clear. These parties have all argued for
the use of RECs, particularly out of state RECs for
compliance with the RPS, with some support from
environmental and ratepayer groups along with the CPUC.
5. Enforcement & Flexible Compliance - Current law requires
the CPUC to enforce a retail seller's compliance with the
RPS. The PUC may fine a retail seller that fails to meet
its year-to-year RPS target. The PUC has set the penalties
at 5 cents for each kilowatt hour a retail seller falls
short of its RPS target. The PUC has capped the total amount
of penalties that can be charged in a year at $25 million.
The CPUC is also required to adopt flexible rules for RPS
compliance, which include situations of insufficient
transmission, including rules permitting the application of
excess procurement from one year to subsequent years, or to
makeup inadequate procurement in one year within no more
than the following three years.
This bill retains the CPUC's fining authority but eliminates
what has become more commonly known as the "transmission
offramp" and other flexible compliance mechanisms. Instead
the CPUC would be permitted to waive penalties if a retail
seller in two instances. First if they could show a
reasonable effort to procure renewable resources and were
unable to do so as a result of circumstances beyond their
control. Second, if the commission determines that they
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<2> The WECC works with regional transmission operators to ensure
the reliability and market efficiencies of the bulk power system
in 14 western states, Alberta and British Columbia. It does not
schedule or control power on California's transmission lines.
have made investments in energy efficiency that resulted in
significantly less demand for electricity.
Many parties express concern and opposition to what they see
as vague standard of reasonableness to measure RPS
compliance efforts. Some opine that the retail seller
should be required to provide clear and convincing evidence
of the effort to comply with the RPS and also include
specific qualifying circumstances for a waiver of penalties
such as insufficient transmission.
There is also substantial concern with the introduction of
energy efficiency investments into the RPS program. Energy
efficiency (EE) is first in California's loading order and
is similar in effect to RPS since both programs are designed
to reduce the air emissions of electrical generation.
However the IOUs are operating under a clear and distinct
separate mandate to achieve specified levels of energy
savings from EE technologies and tools. Since this
obligation exists, some opine that counting EE savings
toward the RPS creates a loophole in the program and
undermines its goals. Additionally, ESPs to which this
provision would also apply in addition to IOUs, are not
regulated by the CPUC and are not in the energy efficiency
business
6. Implementation Trigger - This bill institutes significant
changes in the RPS program by making wholesale changes in
fundamental program provisions as outlined above. However
it also continues the current program laws and rules until
each retail seller reaches its 20 percent RPS goal. The
result will be that the CPUC will continue to apply the
rules it has developed over six years of rulemakings and
decisions to procurement to reach 20 percent but at the same
time adopt new rules which would apply to those retail
sellers at some future date (likely 2013 - 2014) which would
be triggered as each retail seller reaches its 20 percent
goal. There will also likely be confusion as to which rules
apply in certain situations. The new RPS provisions have
two operative dates for each IOU - at January 1, 2011 and
when each IOU reaches its 20 percent goal, calling into
question which rules apply where and when and leaving gaps
in some areas.
7. Transmission - This bill establishes for the first time
the "Energy Planning and Infrastructure Coordinating
Committee" (EPIC) which would be comprised of the CPUC, CEC,
ISO and other agency heads and parties. The author is
clearly responding to the reported challenges of getting new
transmission to remote renewable resources. Sufficient
transmission has been approved to meet the 20 percent RPS
goal. An additional 5 lines are reported to be needed to
reach the 33 percent goal. Planning for those lines is
underway.
Most of the specified planning and duties required of EPIC
already exist in law, regulation or practice by the
participating entities. There is significant concern that
the creation of EPIC would do little more than place a
bureaucratic hurdle in the way of reach the RPS goals that
duplicates the work already underway by other entities and
be disruptive and time-consuming.
The CPUC would also be directed in this bill to complete its
review of an application for a new transmission line within
one year of receiving the completed application. This would
rarely be possible. It is not uncommon for a transmission
line to traverse great distances over land controlled by
many different agencies at the local, state and federal
level as well as private parties and sovereign nations. The
lines require full review under the California Environmental
Quality Act which typically must evaluate the affected
geography across all four seasons - a full year before an
analysis could even be completed. Additionally most lines
touch federal lands requiring review under the National
Environmental Policy Act (NEPA). The CPUC has successfully
negotiated a joint review with the federal agencies but,
still, more than one year is required.
Finally this bill requires the CPUC, if concurred in by the
Division of Ratepayer Advocates, to accept as a rebuttable
presumption, a determination by the ISO that a transmission
line is "needed" to connect renewable generation.
According to the CPUC "this evaluation considers
reliability, economic, and operational benefits of proposed
transmission upgrades" to ratepayers and runs parallel to
the CEQA process. Because it runs parallel, time savings
for CPCN approval are not apparent. More significantly, the
needs evaluation done by the CPUC is done in a
quasi-judicial and public venue with participants from the
affected communities, ratepayers and other parties that are
not part of the ISO's private transmission planning
process. The ISO is a non-profit entity and not subject to
open meetings laws. A transmission line that can cost
ratepayers billions of dollars requires a thorough and
public vetting of its need.
8. Siting of Renewable Resources - The CEC currently sites
all thermal electric generation resources which are sized
over 50 MW. This bill would transfer to the CEC all siting
authority of all eligible renewable resources of 5 MW or
more. Some opine that this change would make it more
difficult for local parties to participate in the planning
process; some parties generally report that the local
process is working well and they see no need for the change.
Additionally, due to the elimination of a definition of an
eligible renewable resource in Public Resources Code Section
25741, the CEC has no direction as to what resources it
would be charged with siting under this new authority.<3>
9. Combined Heat & Power (CHP) - The CEC is charged in this
bill with implementing the provisions of the RPS program in
such a way that the RPS is compatible with achieving 4,000
MW of combined heat and power electrical generation. In its
Scoping Plan to implement AB 32, CARB has identified 4,000
MW of CHP as a potential strategy to reduce GHG emissions.
However, in this instance, the CEC has minimal authority
over RPS procurement and has limited obligations under the
RPS program. It is not clear that the CEC has any ability
to facilitate this provision.
10. Preference for California Suppliers - This bill
requires that the CPUC provide preference to contracts for
eligible renewable energy resources that are from a
California supplier. In practice preference provisions are
not enforceable and may have little effect on IOU or CPUC
---------------------------
<3> A new definition of eligible renewable resource is contained
in provisions of this bill which become effective January 1, 2011
but are not triggered until a retails seller reaches its 20
percent RPS goal.
actions. Moreover if this section was implemented a
particular renewable resource could be chosen based on the
geographic location of a company headquarters rather than
the efficiency and deliverability characteristics of the
generation and price to ratepayers.
11. Similar Legislation - A similar bill, SB 14 (Simitian,
et al) passed this committee in March and is scheduled to be
heard in the Assembly Utilities and Communications Committee
on June 29th.
12. Double Referral - This bill has been double referred to
the Senate Rules Committee. Due to time constraints, if
amendments are proposed in Committee these amendments must
be taken in the Rules Committee.
ASSEMBLY VOTES
Assembly Floor (44-31)
Assembly Appropriations Committee (12-5)
Assembly Natural Resources Committee
(6-3)
Assembly Utilities and Commerce Committee
(8-5)
POSITIONS
Sponsor:
Author
Support:
BP America Inc. (if amended)*
City of Los Angeles Department of Water and Power (if amended)*
Natural Resources Defense Council (if substantially amended)
Planning and Conservation League (if amended)
Union of Concerned Scientists (if amended)
Oppose:
Alliance for Retail Energy Markets (unless amended)
California Farm Bureau Federation*
California Large Energy Consumers Association (unless amended)
California Manufacturers & Technology Association
California Wind Energy Association (unless amended)*
County of Santa Barbara*
Direct Energy (unless amended)
Independent Energy Producers Association
Sanitation Districts of Los Angeles County
Solid Waste Association of North America*
The Utility Reform Network (unless amended)
*Received prior to June 23rd amendments
Kellie Smith
AB 64 Analysis
Hearing Date: June 30, 2009