BILL ANALYSIS                                                                                                                                                                                                    



                                                                  SB 722
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          Date of Hearing:  June 30, 2010

                       ASSEMBLY COMMITTEE ON NATURAL RESOURCES
                                Wesley Chesbro, Chair
                    SB 722 (Simitian) - As Amended:  June 22, 2010

           SENATE VOTE  :  Not relevant
           
          SUBJECT  :  Utilities:  renewable energy resources

           SUMMARY  :  Increases California's Renewables Portfolio Standard  
          (RPS) goal from 20 percent by 2010 to 33 percent by 2020 and  
          revises specified provisions of the existing RPS statutes.

           EXISTING LAW  :

          1)The RPS requires investor-owned utilities (IOUs) and certain  
            other retail sellers of electricity to achieve a 20 percent  
            renewable energy portfolio by 2010 and establishes a detailed  
            process and standards for renewable energy procurement.

             a)   Requires local publicly-owned utilities (POUs) to  
               implement and enforce their own RPS programs.  POUs are not  
               subject to the same detailed process and standards as IOUs  
               and other retail sellers subject to the jurisdiction of the  
               Public Utilities Commission (PUC).

             b)   Provides that eligible renewable technologies are  
               biomass, solar thermal, photovoltaic, wind, geothermal,  
               renewable fuel cells, small hydroelectric (30 megawatts or  
               less), digester gas, limited non-combustion municipal solid  
               waste conversion, landfill gas, ocean wave, ocean thermal,  
               and tidal current.

             c)   Provides that renewable resources located outside the  
               state are eligible if the facility commences operation  
               after January 1, 2005 and is connected to California's  
               transmission grid or delivers energy to California.

             d)   Defines and permits the use of unbundled/tradable  
               renewable energy credits (RECs) for RPS compliance, subject  
               to PUC approval, and authorizes the PUC to limit the amount  
               of RECs a retail seller may use for RPS compliance.

             e)   Requires IOUs to submit annual RPS procurements plans  








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               and meet a one percent per year annual procurement target.

             f)   Requires the PUC to adopt a market price referent (MPR)  
               as a benchmark for reasonable prices for RPS procurement by  
               IOUs.

             g)   Designates funds (approximately $165 million per year)  
               available to cover IOUs' RPS procurement costs which exceed  
               the MPR.  Once these funds are exhausted, IOUs are relieved  
               of their obligation to buy additional renewable energy  
               through the RPS procurement process, but may build or  
               continue to buy renewable energy through bilateral  
               contracts, notwithstanding this RPS "cost cap."

             h)   Permits specified small, multi-jurisdictional IOUs to  
               count renewable energy delivered in other states under  
               specified conditions.

          2)Requires the PUC to certify the public convenience and  
            necessity require a transmission line before an IOU may begin  
            construction (Certificate of Public Convenience and Necessity,  
            or CPCN).  The CPCN process includes environmental review of  
            the proposed project under the California Environmental  
            Quality Act (CEQA).

          3)The California Global Warming Solutions Act (AB 32) requires  
            the Air Resources Board (ARB) to adopt a statewide greenhouse  
            gas (GHG) emissions limit equivalent to 1990 levels by 2020  
            and adopt regulations to achieve maximum technologically  
            feasible and cost-effective GHG emission reductions.  Pursuant  
            to AB 32, ARB has adopted a Scoping Plan which includes  
            achieving a 33 percent RPS by 2020 as a key measure to achieve  
            the 2020 GHG emissions limit and, pursuant to Governor's  
            Executive Order S-21-09, initiated a rulemaking to adopt the  
            standard.

           THIS BILL  :

                                        Targets
           
          1)Replaces the existing 20 percent by 2010 RPS target and one  
            percent annual procurement targets applicable to "retail  
            sellers", which include IOUs, energy service providers and  
            community choice aggregators, with the following targets:









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             a)   20 percent by December 31, 2012.

             b)   25 percent by December 31, 2016.

             c)   33 percent by December 31, 2020 and each year  
               thereafter.

            Instead of regular annual procurement targets, each of these  
            targets is preceded by a compliance period where the quantity  
            of renewable energy procured must reflect reasonable progress  
            in the intervening years sufficient to meet the next target.

          2)Revises existing provisions requiring POUs to implement and  
            enforce their own RPS programs and instead requires POUs to  
            achieve the following specific targets:

             a)   20 percent by December 31, 2013.

             b)   25 percent by December 31, 2016.

             c)   33 percent by December 31, 2020.

                                   Compliance Delays
          
          3)Authorizes the PUC to allow retail sellers to delay compliance  
            with any renewable procurement requirement if the retail  
            seller demonstrates that any of the following conditions are  
            beyond its control and will prevent timely compliance:

             a)   Inadequate transmission capacity for delivery of  
               sufficient renewable energy.

             b)   Unanticipated permitting, interconnection or "other"  
               delays for renewable energy projects, or an insufficient  
               available renewable energy.

             c)   Unanticipated curtailment of renewable energy necessary  
               to address the needs of a balancing authority (e.g. the  
               Independent System Operator) or a transmission owner (e.g.  
               a utility).

                                      Eligibility
           
          4)Revises eligibility conditions to establish "balanced  
            portfolio" requirements for future procurement based on the  








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            following three categories of renewable energy products:

             a)   Renewable energy interconnected to the grid within,  
               scheduled not less than hourly for direct delivery into, or  
               dynamically transferred by, a California balancing  
               authority (i.e., real renewable energy supplied to the  
               California grid, located within or directly proximate to  
               the state).  At least 75 percent of the portfolio must fall  
               into this category.

             b)   Renewable energy where substitute non-renewable energy  
               is used to provide a reliable delivery schedule into a  
               California balancing authority, provided the substitute  
               energy meets California's greenhouse gas emission  
               performance standard (i.e., firmed and shaped energy where  
               substitute energy is used to compensate for delivery  
               problems due to intermittent generation or inadequate  
               transmission capacity from a remote renewable resource).

             c)   Renewable energy products not meeting either condition  
               above, including unbundled RECs (i.e., the original source  
               of renewable energy must be located within the western  
               grid, but otherwise need not have a physical connection to  
               California).  Not more than 10 percent of the portfolio may  
               fall into this category.

          5)Provides that renewable resources located outside the state  
            are eligible if the facility commences operation after January  
            1, 2010, unless electricity generated by the facility was  
            procured by a retail seller or POU as of May 31, 2009.

          6)Requires the PUC to authorize the use of RECs, subject to  
            limits described above, and limits the use of RECs to 18  
            months from the initial date of generation of the associated  
            electricity.

                                   Cost Containment
           
          7)Repeals existing MPR, above-market funds and cost cap  
            provisions and instead authorizes the PUC to establish a cost  
            limit for each IOU according to specified criteria.  (Revised  
            by amendments agreed to in Utilities and Commerce Committee,  
            noted in comments below.)

                                         Other








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          8)Sets aside 25 percent of the 33 percent renewable market for  
            IOU-owned generation by requiring the PUC to approve an  
            application by an IOU to construct, own and operate a  
            renewable energy facility until IOU-owned renewable facilities  
            equal 8.25 percent of the IOU's anticipated 2020 retail sales.

          9)Requires the CEC, in consultation with ARB, to adopt  
            regulations for enforcement of the RPS on POUs, including  
            providing for the imposition of penalties by ARB pursuant to  
            AB 32, upon referral by the CEC, for failure to comply with  
            the RPS.

          10)Provides additional assurance of recovery by IOUs of costs  
            incurred for transmission facilities the PUC finds are  
            reasonably necessary or appropriate to facilitate achievement  
            of the RPS.

          11)Requires the PUC to approve an application to construct a  
            transmission line within 18 months under specified conditions.

          12)Appropriates $322,000 from the PUC Utilities Reimbursement  
            Account to the PUC for additional staffing related to  
            transmission lines.

          13)Requires the Department of Fish and Game to establish an  
            internal division to perform comprehensive planning,  
            streamlined environmental compliance services, and ensure  
            timely completion of Natural Community Conservation Plans  
            related to development of renewable energy projects.

           FISCAL EFFECT  :  Unknown

           COMMENTS  :

           1)Background.   The RPS requires IOUs and certain other retail  
            energy providers, collectively referred to as "retail  
            sellers," to buy renewable electricity to the extent funds are  
            available to pay for any costs exceeding a market price set by  
            the PUC.  Each IOU is required to increase its renewable  
            procurement each year by at least one percent of total sales,  
            so that 20 percent of its sales are renewable energy sources  
            by December 31, 2010.  Once a 20 percent portfolio is  
            achieved, no further increase is required.  The PUC is  
            required to adopt comparable requirements for direct access  








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            energy service providers and community choice aggregators.

            The RPS requires the PUC to adopt processes for determining  
            market prices, ranking renewable bids according to cost and  
            fit, flexible compliance rules and standard contract terms.   
            The RPS requires IOUs to offer contracts of at least 10 years,  
            unless the PUC approves shorter contracts.  This is intended  
            to support the development of new renewable resources.

            The original RPS bill, SB 1078 (Sher), Chapter 516, Statute of  
            2002, set a goal of 20 percent by 2017.  SB 107 (Simitian),  
            Chapter 464, Statutes of 2006, accelerated the deadline for 20  
            percent to 2010.  Nearly eight years after the RPS was  
            enacted, IOUs have advanced beyond their 2002 average starting  
            point of 12 percent RPS, but are not on pace to achieve 20  
            percent by the end of this year, and intend to rely on  
            flexible compliance rules to delay attainment of 20 percent  
            until 2013.  According to the PUC, in 2009, the IOUs served  
            15.4 percent of their load with renewable energy, up from 13  
            percent in 2008.  PG&E achieved 14.4 percent, SCE 17.4   
            percent and SDG&E 10.5 percent.

            Last year, the Governor vetoed two bills passed by the  
            Legislature to establish a 33 percent RPS -  SB 14 (Simitian)  
            and AB 64 (Krekorian).  Following the vetoes, the Governor  
            issued an executive order directing ARB to implement a 33  
            percent RPS as a GHG reduction measure pursuant to its  
            authority under AB 32.  ARB has initiated a rulemaking to  
            establish a "renewable electricity standard" (RES), with  
            adoption by the board scheduled for July 2010.  However,  
            questions have been raised regarding the permanence and  
            legality of an RES regulation based on an executive order. 

           2)Excuses, excuses?have this bill's renewable targets taken a  
            back seat to compliance off-ramps?   This bill attempts to  
            strike a balance between establishing ambitious renewable  
            targets, facilitating the necessary renewable procurement and  
            infrastructure development, and tempering the targets by  
            providing utilities flexibility if they encounter compliance  
            challenges.  The bill recognizes situations where a utility's  
            good faith efforts to achieve renewable targets might be  
            frustrated by circumstances beyond its control, such as  
            inadequate transmission infrastructure or unanticipated  
            permitting delays.  However, the bill seems to give utilities  
            too little credit for the helpful role that they can and  








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            should play in developing the infrastructure necessary to  
            achieve a 33 percent RPS.  In general, the excuses for  
            compliance delays in the bill should be subject to review and  
            approval of the PUC in a transparent process, clearly limited  
            to circumstances beyond a utility's control, and limited to  
            the time necessary to remedy the problem or find an  
            alternative.  In particular, a utility should not be eligible  
            for a compliance delay where the utility has a potential  
            conflict or incentive to stall, such as curtailing delivery of  
            renewable energy on its own transmission lines.

           3)Suggested amendments:

              a)   On page 18, line 19, strike out "2013" and insert  
               "2012".  

              b)   On page 20, line 1, strike out "The definition of  
               'delivered' and 'delivery'" and insert "This Article".  

              c)   On page 20, line 3, strike out "deliver" and insert  
               "supply".  

              d)   On page 20, line 9, strike out "deliver" and insert  
               "supply".  

              e)   On page 20, line 13, strike out "the delivered" and  
               insert "these".  

              f)   On page 25, line 38, strike out "in-state".  

              g)   On page 32, line 4, strike out strike out "assume" and  
               insert "require".  

              h)   On page 33, line 15, after "other" insert "related".  

              i)   On page 34, strike out lines 8-11 and insert a period.  

              j)   Conform amendments to Section 399.2.5 (Section 10) and  
               Section 399.12(g)(3) to amendments to those sections made  
               by AB 1954 (Skinner).  













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          4)Amendments recommended by Utilities and Commerce Committee.    
            When this bill was approved by the Utilities and Commerce  
            Committee June 24, the author and committee agreed to  
            amendments, with adoption deferred to this committee.  In  
            summary, the U&C amendments:

             a)   Amend findings to require the PUC to ensure that rates  
               are just and reasonable and not significantly affected by  
               the RPS.

             b)   Require the PUC to establish a cost limit.

             c)   Require the PUC to report to the Legislature by 2016  
               regarding whether IOUs can achieve 33 percent within the  
               adopted cost limit.

             d)   Authorize the PUC to revise the cost limit once after  
               2016 if necessary.

             e)   Authorize IOUs to stop procuring renewable energy beyond  
               the cost limit.

             f)   Require the PUC to report annually regarding the efforts  
               the utilities are taking in recruiting and training  
               employees to ensure an adequately trained and available  
               workforce.

             g)   Require the PUC, in its process for ranking renewable  
               energy resources according to "least-cost and best-fit," to  
               take into account the workforce recruitment, training, and  
               retention efforts associated with the construction and  
               operation of the eligible renewable energy project.

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          California Biomass Energy Alliance (if amended)
          Independent Energy Producers (if amended)
          Large-scale Solar Association
          Solar Alliance
           
            Opposition 
           
          Alliance for Retail Energy Markets (unless amended)








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          California Manufacturers & Technology Association


           Analysis Prepared by  :  Lawrence Lingbloom / NAT. RES. / (916)  
          319-2092