BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 1150
                                                                  Page  1

          Date of Hearing:   April 25, 2011

                    ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE
                               Steven Bradford, Chair
               AB 1150 (V. Manuel Perez) - As Amended:  April 25, 2011
           
          SUBJECT:   Self-generation incentive program.

           SUMMARY:  Extends the sunset date for the annual collection of 
          the Self Generation Incentive Program (SGIP) through December 
          31, 2016 and authorizes the Public Utilities Commission (PUC) in 
          consultation with the California Energy Commission (CEC) to 
          continue to administer the program until January 1, 2018.  
          Specifically, this bill:

          1)Extends the sunset date for the SGIP through December 31, 2016 
            to authorize the investor owned utilities (IOUs) to continue 
            the annual collection of $83 million in ratepayer funds for 
            SGIP and extends the administration of the program through 
            January 1, 2018.

          2)Provides that the PUC may adjust the amount of SGIP incentives 
            and evaluate other public          policy interest such as, 
            job development, technology competitiveness, maximizing fund 
            development across all technologies, localized energy 
            generation deployment, protection of ratepayers, energy 
            efficiency, peak load reduction, load management, and 
            environmental interests.  

          3)The bill also caps the maximum amount of incentives a company 
            can earn to no more than 25% of the annual amount of money 
            collected for SGIP and restricts the per watt rebate to $2.50.

          4)Includes intent language signaling that the program should 
            increase deployment of distributed generation and distributed 
            storage systems to facilitate integration of those resources 
            into the electrical grid and reduce ratepayer costs.  

           EXISTING LAW:   

          1) Authorizes the PUC to administer the SGIP to provide rebates 
          for distributed generation (DG) technologies until January 1, 










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          2016, and to authorize electrical corporations to annually 
          collect not more than the amount authorized for the SGIP in the 
          2008 calendar year through December 31, 2011.

          2) Limits eligibility for incentives to distributed energy 
          resources that the PUC in consultation with the State Air 
          Resources Board, determines will achieve reductions in emission 
          of greenhouse gases pursuant to the California Global Warming 
          Solutions Act of 2006.

           FISCAL EFFECT:   Unknown.

           COMMENTS:   According to the author of the bill, "AB 1150 will 
          permit the extension of a vital program for incentivizing the 
          development of distributive on-site renewable energy facilities. 
          These are needed to meet increasing statewide demand for 
          electricity, to reduce peak demand pressures on the grid and 
          help meet California public policy goals of reducing greenhouse 
          gas emissions and increase the supply of clean renewable 
          energy."  The bill is sponsored by the Foundation Windpower and 
          they claim that, "under current law, SGIP will receive no new 
          funds after 2011 and, while the program itself will not expire 
          until 2016, the Public Utilities Commission projects will have 
          little or no funds left in the program after 2011."  Therefore, 
          AB 1150 is needed to "authorize the collection of new ratepayer 
          funds through 2018 and would extend the period for making 
          incentive payments available through 2016.

           BACKGROUND:   During the 2000-01 energy crisis the PUC was 
          directed to create a program of incentives for renewable and 
          super clean, gas-fired distributed generation resources to 
          reduce electricity demand.  As a result, the PUC established the 
          SGIP in March 2001 which has offered rebates for installation of 
          technologies such as photovoltaics, wind, fuel cells, waste gas, 
          and ultra-clean and low emission gas-fired distributed 
          generation (combined heat and power, CHP).  Legislation adopted 
          in 2004 eliminated CHP from the program as of January 1, 2008.  
          In 2006 photovoltaic incentives were moved out of the SGIP to 
          the California Solar Initiative (CSI) effective January 1, 2007. 
           With the passage of AB 2778 (Lieber) Chapter 617, Statutes of 
          2006, only fuel cell and wind technologies were eligible for 
          incentives.  AB 2267 (Fuentes) Chapter 537, Statutes of 2008, 










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          established a 20% rebate incentive bonus for California 
          suppliers and SB 412 (Kehoe) Chapter 182, Statutes of 2009, 
          extended SGIP to 2016 and charges PUC with selecting eligible 
          GHG reducing technologies for inclusion in SGIP.
           
          SGIP Funding  . The program is funded by a charge on all 
          ratepayers (CARE customers are excluded) which is reflected in 
          the distribution charges paid in each billing.  This costs the 
          ratepayer less than $5 dollars per year.  According to the PUC, 
          the SGIP program has completed 1,320 self-generation projects 
          for 355MW and still has an additional 169 pending projects for 
          82 MW.  Since the inception of the program in 2001 until now, 
          $865 million has been available to customers under SGIP.  The 
          SGIP budget was initially set at $125 million per year in 2001, 
          with cost responsibility allocated across ratepayers of the 
          Investor-Owned Utilities (IOUs).  With the creation of the 
          California Solar Initiative (CSI) in 2006, the PUC redirected 
          the portion of the SGIP budget that supported solar photovoltaic 
          incentives into the CSI program, which does not include 
          SoCalGas, since it does not have a CSI program.  As a result, 
          the SGIP budget was reduced to $83 million per year for 2007 and 
          2008 to reflect the elimination of the solar photovoltaic 
          incentives that CSI now funds.  That budget level was maintained 
          for 2010 and 2011 by D.09-12-047; the PUC adopted an annual 
          budget of $83 million for the SGIP in 2010 and 2011. In that 
          decision, the PUC ordered the PA's to obtain an independent 
          entity to conduct an audit of the SGIP expenditures and 
          ratepayer collections to ensure expenditures do not exceed 
          authorized budgets and the proper management of carryover funds 
          (will be discussed later). 

          SGIP provides $83 million ($75 million for incentives, $8 
          million for program administration) per year until December 31, 
          2011 when collection of the funds sunsets.  Incentive budget 
          splits 50% for renewable and 50% for non-renewable.  SGIP offers 
          upfront incentives to offset the cost of capital investment.  
          Incentive payments are $1.50 per watt for wind turbines, $2.50 
          per watt for fuel cells, $4.50 per watt for biogas fuel cells, 
          $2.00 per watt for storage, and $2.50 for natural gas.  
          According to the PUC, the maximum eligible system size is 5 MW 
          per site, or the load limited system size whichever is less.  
          For systems larger than 1 MW, the maximum incentive is capped at 










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          3 MW per site.  However, incentives are lower for projects above 
          1 MW on the portion of their SGIP funded system(s) that exceed 
          1MW for that site based upon a tiered incentive structure 
          approved by the PUC.
          
          SGIP Program Budget Status, $ Millions (Compiled on February 2, 
          2011)
          
           ---------------------------------------------------------------------- 
          |        |Reported    |Received    |Budget as   |2011 Budget |Budget   |
          |        |Budget      |Between     |of          |            |Remaining|
          |        |Available   |12/22 and   |12/31/2010  |            |         |
          |        |as of       |12/31/2010  |if Motion   |            |including|
          |        |12/22/2010  |            |is          |            | 2011    |
          |        |            |            |Effective   |            |Budget   |
          |        |            |            |12/31/10    |            |         |
          |--------+------------+------------+------------+------------+---------|
          |Renewabl|$ -17.40    |$ 24.37     |$ -41.77    |37.5        |-4.27    |
          |e       |            |            |            |            |         |
          |Budget  |            |            |            |            |         |
          |--------+------------+------------+------------+------------+---------|
          |Non-Rene|$ 110.37    |$ 41.60     |$ 68.77     |37.5        |106.27   |
          |wable   |            |            |            |            |         |
          |Budget  |            |            |            |            |         |
          |--------+------------+------------+------------+------------+---------|
          |Cumulati|$ 92.97     |$ 65.96     |27.00       |75.0        |102.0    |
          |ve      |            |            |            |            |         |
          |Budget  |            |            |            |            |         |
           ---------------------------------------------------------------------- 
          Note: All figures in $ Millions.  A negative number implies a 
          waitlist figure.

           Implementation of SB 412:   On October 11, 2009, the Governor 
          signed SB 412 (Kehoe), Chapter 182, Statutes of 2009, into law 
          to take effect in January 2010 which extended the administration 
          of the SGIP program until 2016 but sunsets the collection of the 
          funds in 2011, SB 412 did not extend authorization to collect 
          funds for the program.  Importantly, SB 412 authorizes the PUC, 
          in consultation with the California Air Resources Board (CARB), 
          to determine eligible technologies for the SGIP based on the 
          requirement that they "achieve reductions of greenhouse gas 
          emissions pursuant to the California Global Warming Solutions 










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          Act of 2006 and consider adding additional technologies to the 
          program that meet these requirements.  

          Pursuant to SB 412, the PUC opened a new rulemaking, R.10-05-004 
          to continue to handle matters related to the SGIP and CSI 
          programs and revise the staff proposal intended to assess 
          eligible technologies, incentive levels, and incentive 
          structure.  The purpose of the Energy Division Staff Proposal is 
          to recommend modifications to the SGIP program.  PUC staff used 
          the opportunity provided by SB 412 to take a broader look at 
          SGIP and consider a full range program modifications intended to 
          improve program outcomes which could address some of the 
          concerns mentioned above.  The proposal would only provide 
          preliminary recommendations on the SGIP program goals and 
          principles and staff intends to update certain identified 
          portions of this proposal in response to information expected in 
          the future.  On January 7, 2010, the PUC hosted a workshop to 
          take ideas from parties on how to modify the program in response 
          to SB 412.  This proposal is still pending and until now has not 
          been released.  

           PG&E Motion to Temporary Suspend SGIP:    On May 6, 2010, the 
          Pacific Gas and Electric (PG&E) and the SGIP Program 
          Administrators (PA) including Southern California Edison, 
          Southern California Gas Company, and the Center for Sustainable 
          Energy requested that the PUC temporarily suspended the SGIP 
          program to become effective December 22, 2010, until the 
          decision of implementing SB 412 is approved by the PUC and takes 
          effect.  They were concerned that unless a moratorium on new 
          applications is put in place, projects of currently eligible 
          technologies could consume all available SGIP funding.  
          According to the PUC, applications submitted in the 2010 program 
          year were granted due process rather than suspending the program 
          as PG&E requested.  However, new applications for the 2011 year 
          were suspended.   The PUC reported that some SGIP PAs stopped 
          accepting applications as of December 22, 2010.  However, there 
          was still a waitlist for $17 million in renewable projects and 
          $24 million more renewable projects received in last nine days 
          of the year.  As of December 22, 2010, there was $110 million 
          available for non-renewable projects, and $41 million were 
          received in the last nine days of the year. 
           










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          PUC's Independent Audit Report:   Under existing law, SGIP 
          encourages merit-based competition on a first come first serve 
          basis among distributed energy technologies, promoting 
          technology innovation and allowing Californians to install the 
          clean energy solution that best meets their needs.  However, it 
          was represented that certain technologies were benefiting from 
          incentives more than others and that there were inaccuracies in 
          reporting.  As a result, the PUC ordered participating utilities 
          to have a third party audit the SGIP budget to resolve any 
          questions about available funds.  

          The PUC commissioned the audit based on budget discrepancies 
          between expenditures and ratepayer collections for the period 
          2001-2009.  The PUC released its audit and placed it on its 
          website on April 13, 2011.  The audit cost $250,000 and was paid 
          for by the SGIP administrative, measurement, and evaluation 
          budget.   PUC decisions set the SGIP budget at an annual maximum 
          of 10 percent for each Program Administrator (PA) for 
          administration costs.  However, the audit reported that there 
          has been some unspent administration monies that have been 
          transferred to the incentive budgets.  Due to the different 
          reporting styles of some of the PAs it is unclear to know if all 
          carryover administration funds have actually been used for 
          incentives.  PG&E, for example had unspent admin monies in the 
          amount of $56 million which were transferred to incentive 
          budgets between 2001 and 2009.  The biggest issue identified was 
          a need for more consistent reporting and better accounting 
          (e.g., recording incentives paid in the year a reservation of 
          incentives is granted as opposed to the year an application is 
          received).  Many of the discrepancies between reservation 
          amounts and actual incentives paid can be explained by changes 
          in project size after a reservation is granted or limitations on 
          maximum incentives that can be paid.  

           Accountability:  Currently, the PUC requires PAs to report their 
          portfolio quarterly.  Perhaps better accountability from the PUC 
          and PAs needs to be addressed to ensure that there are no 
          discrepancies and ensure that if there are unused administration 
          funds that they be transferred to be used for incentives.  The 
          PUC has already started implementing some of the audit's 
          recommendations including, revamping the PUC's statewide 
          database, which will facilitate automated reporting, include an 










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          interactive database, and most importantly, impose uniform 
          reporting requirements.  As for the PG&E office remodeling that 
          was reported in the audit, while it may not seem like an 
          appropriate administrative expense, utilities usually seek cost 
          recovery for this type of activity in their general rate cases.  
          PUC should not allow this to happen and provide more oversight 
          over the PAs. 

           Who Pay's and Who Benefits:   According to critics of the SGIP 
          program, this $83 million is ratepayer money that is being used 
          to subsidize large companies.  The proponents argue that the 
          SGIP program has substantial benefits to ratepayers such as 
          providing construction and operation jobs within the state; 
          reducing stress on the grid during peak consumption hours; 
          mitigating the expensive cost of transmission and distribution 
          lines; and providing incentives to promote localized clean power 
          near the load center.  Additionally, SGIP was intended to 
          incentivize market transformation for those technologies that 
          meet the policy goals of promoting in-state manufacturing and 
          ensuring GHG emission reductions.  In this way, SGIP is public 
          policy that benefits all Californians regardless of whether they 
          participate in the program directly or not. Those who do 
          participate directly lower their energy bills on site while 
          everyone benefits from that participation in the ways outlined 
          above.  SGIP is a smart investment for ratepayers because it 
          provides upfront incentives for customers who install clean 
          energy projects, with the customers still covering the majority 
          of the costs.  Without these incentives most projects would not 
          go forward.  Large scale utility procurement projects often cost 
          in the billion dollar range, with high transaction costs and 
          where the ratepayer most often bares all the cost risk. By 
          making smaller investments that leverage private equity, the 
          ratepayer and the customer see reduced transaction costs.  More 
          importantly, with the help of SGIP, customers like Adobe, eBay, 
          Safeway, Staples, and others, are reducing their electricity 
          costs which enables them to become more competitive in the 
          global economy and enables them to keep prices down for their 
          customers

           Benefit to the Residential Ratepayer:   SGIP program costs the 
          residential ratepayer less than $5 a year and supports 
          residential applications.  For example, Clear Edge Power a 










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          company from Portland, Oregon, provides fuel cell for 
          residential applications.  In one year there have been about 83 
          applications for this product by residential customers.  As 
          other companies scale, they will lower their costs and be able 
          to sell a residential product as well.  Furthermore, the 
          programs is helping grow our economy since these ratepayer 
          funded incentive dollars, leveraged by over $1 billion dollars 
          of  capital investment from investors around the world, have 
          fueled thousands of jobs and significant economic impact into 
          our state's economy.

          For instance, Bloom Energy's advanced fuel cell technology was 
          invented in California, is manufactured in California and is 
          generating clean distributed power for Californians.  Because of 
          the growing customer demand enabled by SGIP, Bloom Energy grew 
          its California employee base by 70% in 2010, and over 525% over 
          the past four years.  Ten years ago Bloom was 8 people; now 
          Bloom is responsible for 1,000 California jobs.  Bloom's 
          California manufacturing and operations footprint grew four 
          times over the past year and Bloom has gone from manufacturing 
          one fuel cell system per month two years ago to one system per 
          day in 2011.  If the SGIP customer is a business all of those 
          who do transactions with that business will also see lower 
          prices down stream.  For example, if ABC Grocery, for instance, 
          reduces its energy costs the customer of ABC Grocery also sees 
          reduced costs as ABC Grocery would otherwise pass on high energy 
          costs to their customer.  

           
          Stakeholder's Concerns:
           PG&E currently does not have a position on the bill, but they do 
          believe that the implementation of SB 412 will answer many of 
          the questions about what technologies should qualify and how 
          incentives should be determined and allocated.
           
           Bloom Energy, TechNet, Environmental Defense Fund, and a 
          coalition of consumers strongly support the extension of the 
          SGIP program to continue to promote and enable clean energy 
          engineering, manufacturing and installation jobs in California.  
          They also suggest that the PUC should ensure a fair allocation 
          of the SGIP funding so that no company's technology monopolizes 
          SGIP funding but strongly opposes and encourages to "delete 










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          incentive caps from AB 1150."  They believe SGIP legislation 
          should take a technology-neutral approach; and that it should 
          authorize the PUC to continue to enable increased diversity in 
          our state's energy mix, and may include declining incentives as 
          appropriate to ensure ratepayer subsidies support market 
          transformation, not a long-term crutch. 

          The Utility Reform Network (TURN) has concerns with the 
          authorization to continue the collection of $83 million a year 
          for another five years to spend on the SGIP program.  Their 
          primary concern is that ratepayers do not benefit from this 
          program since most of the SGIP projects are almost exclusively 
          installed by larger commercial and industrial customers to 
          generate electricity for their own use.  TURN also mentions that 
          to spend another $415 million or more on this program is "unfair 
          to residential utility customers and violates the deal struck in 
          SB 412."  They recommend that the problem could be fixed by 
          requiring that the costs of this program be allocated to the 
          customer's class whose members benefit from the program 
          subsidies.  

          The Sonoma County Water Agency believes AB 1150 should provide 
          equal incentives for all renewable energy sources since the 
          current language in the bill could be interpreted to favor one 
          type of renewable energy over another by offering a higher 
          incentive rates for certain technologies.  They recommend that 
          the same incentive be offered for all renewable technologies 
          including biogas projects using biodigester and landfill gas 
          energy sources.  They also believe that the SGIP program should 
          increase allowable project size since currently the program sets 
          declining incentive rates for projects larger than 1MW.  They 
          recommend that the allowable project size limit be removed, and 
          that the full incentive be made available for up to 5MW of power 
          generation, and that projects be sized to serve all or a portion 
          of the host customer's power load regardless of location.    
           
          Are we playing leap frog?   The PUC is currently in the process 
          of implementing SB 412, which may address some of the issues 
          brought up in this bill such as, adjusting the current SGIP 
          incentive levels.  According to the PUC's initial staff 
          proposal, they are working to consider changes in incentive 
          tiers, similar to the declining CSI incentive design, which 










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          declines the incentive as more solar is developed.  In 2007, 
          when the CSI program began, the incentive for solar PV was $2.50 
          per watt now it is as low as $0.35 per watt in some service 
          territories.  However, for the SGIP program this structure might 
          not work since there are different technologies and the 
          relatively small number of projects of each technology makes it 
          difficult to establish a MW trigger for declining incentives but 
                                                                   the PUC can have technology specific declining incentives.  Even 
          if this staff recommendation is preliminary, the PUC is looking 
          to adopt a 10% incentive decline starting on January 1, 2012 
          which should decline by 10% annually.  Placing a cap of 25% per 
          company and a $2.50 per watt incentive essentially takes away 
          the PUC's authority to adjust the incentive level (which they 
          are working on) and placing it in statute will create a 
          precedent which will require legislative modification of the 
          incentive levels.  This committee is interested in seeing that 
          the PUC will ensure equitable distribution of funding to all 
          eligible technologies and program participants and that the PUC 
          should assess technology penetration in underserved regions of 
          the state affected by environmental blight and economic stress.  
           The author and this committee may wish to amend this bill to 
          remove the 25% per company cap and the $2.50 per watt cap.  The 
          committee may also wish to amend the bill to require the PUC to 
          periodically evaluate the program to adjust the amount of 
          rebates and other program design elements to ensure that there 
          is equitable distribution of incentives to all eligible 
          technologies and program participants and assess technology 
          penetration in underserved areas of the state that are 
          environmentally blighted and economically stressed.

          Prior Legislation
           Last year, SB 412 (Kehoe) extended the sunset date of the 
          Self-Generation Incentive Program (SGIP) through January 1, 
          2016, restricted the amount the PUC can direct the utilities to 
          collect, and expanded the eligible resources to include all 
          self-generation technologies PUC determines will support the 
          state's goals for the reduction of emissions of greenhouse 
          gases, that meet specified efficiency standards.
           

          REGISTERED SUPPORT / OPPOSITION  :   
           










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          Support 

           A123 Systems, Inc.
          Associated General Contractors of America
          Bloom Energy (if amended)  
           California Business Properties Association
          California Energy Storage Alliance (CESA)
          California Institute of Technology (Caltech)
          California Large Energy Consumers Association (CLECA)
          California Manufacturers & Technology Association (CMTA)
          CALMAC Manufacturing Corporation
          CalWEA
          Capstone Turbine Corporation
          Cemex
          Clean Power Campaign (if amended)
          Debenham Energy LLC
          Deeya Energy, Inc.
          EnerVault Corporation
          Fluidic Energy
          Foundation Windpower (Sponsor)
          Fuel Cell and Hydrogen Energy Association (FCHEA)
          Greensmith Energy Management Systems, LLC
          Ice Energy, Inc.
          LightSail Energy, Inc.
          Mitsubishi Cement Corporation
          Pacific Environment
          Pacific Environment
          Powergetics, Inc.
          Prudent Energy Corporation
          RES Americas, Inc.
          Saft America
          Samsung SDI America, Inc.
          Seeo, Inc.
          Silent Power, Inc.
          Solar Turbines Incorporated (if amended)
          Sonoma County Water Agency (if amended)
          Sumitomo Electric
          SunEdison
          Sunverge Energy, LLC
          SustainX, Inc.
          UTC Power Corporation (if amended)
          Xtreme Power, Inc.










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          Younicos, Inc.

           Opposition   
                         
           The Utility Reform Network (TURN) (unless amended)

           Analysis Prepared by:  Crystal Quezada / U. & C. / (916) 319-2083