BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  SB 1122
                                                                  Page  1

          Date of Hearing:   June 25, 2012

                    ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE
                               Steven Bradford, Chair
                     SB 1122 (Rubio) - As Amended:  June 18, 2012

           SENATE VOTE  :   38-0
           
          SUBJECT  :   Energy: renewable biomass and biogas projects.

           SUMMARY  :   Requires statewide procurement of up to 250MW of 
          renewable energy from small biomass or biogas technologies that 
          utilize low emission technologies.  Specifically,  this bill :

          1)Requires the California Public Utilities Commission (PUC), by 
            June 1, 2013, to allocate 250 megawatts (MW) of biomass/biogas 
            procurement by the state's three major investor owned 
            utilities (IOUs).

          2)Limits each project to no larger than 5 MW.

          3)Allocates procurement by technology as follows:

             a)   Dairy digester gas, 85 megawatts
             b)   Biogas from wastewater treatment, 50 megawatts
             c)   Agricultural biomass and biogas, 50 megawatts
             d)   Biomass using byproducts of sustainable forest 
               management, 30 megawatts
             e)   Landfill gas and organic waste diversion, 35 megawatts

          1)Strongly encourages Public Owned Utilities (POUs) to consider 
            and adopt, if appropriate, a procurement target for small and 
            community-scale biomass and biogas projects.
           
          EXISTING LAW  :

          Existing law requires all IOUs and POUs that serve more than 
          75,000 retail customers, to develop a standard contract or 
          tariff (aka feed-in-tariff or FIT) available for renewable 
          energy facilities up to 3 megawatts (MWs).  Statewide 
          participation is capped at 750 MWs. (399.20 and 387.6 Public 
          Utilities Code)

           FISCAL EFFECT  :   Unknown









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           COMMENTS  :   

           1)Author's Statement.   SB 1122 establishes a statewide 
            procurement requirement of 250 MW from small (less than 5 MW) 
            renewable biomass or biogas projects that utilize low-emission 
            technologies from landfills and organic waste diversion 
            facilities, waste water treatment plants, food and 
            agricultural processing facilities, animal waste facilities, 
            and farms.  It requires the PUC to allocate the 250 MW among 
            the state's three major IOUs.  The PUC's Decision revising the 
            Feed-in Tariff Program ignores market considerations for small 
            renewable biomass or biogas projects and fails to promote 
            diversity in resource technologies. Without differentiating 
            small renewable biomass and biogas projects from other 
            renewable distributed generation technologies, opportunities 
            for methane pollution reduction and clean energy generation 
            will not be realized.  Unless and until the PUC accounts for 
            benefits to ratepayers and the environment from reducing air 
            pollution and global warming emissions by generating 
            electricity from small renewable biomass and biogas, a 
            separate procurement requirement for these technologies is 
            necessary. 

            As highlighted in a recent report from the California Energy 
            Commission (CEC), California's biopower industry has been 
            stagnant for over twenty years, a time period during which 
            wind and solar have performed strongly. When comparing 
            biopower results in the United States to leading biopower 
            markets around the world like Germany, the contrast is stark.  
            The intent of SB 1122 is to unleash a growth spurt in 
            California's biopower market, like what has been experienced 
            in leading biopower markets around the world.

           2)What is a Feed-in-Tariff  ?  A FIT should be a simplified 
            contracting mechanism for small renewable generators to sell 
            power to a utility at predefined terms and conditions, without 
            contract negotiations.  For the IOUs, the FIT operates as a 
            "must-take" contract in its portfolio.  If the participant 
            generates the power, the IOU must take it and pay for 
            generation from the facility according to the terms of the FIT 
            contract.

           3)Federal Law regulates wholesale electricity rates.   Because a 
            FIT is a set rate that is paid for by utilities the 
            electricity generation, the PUC must consider federal law when 








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            establishing the FIT.  The Federal Power Act grants the 
            Federal Energy Regulatory Commission (FERC) jurisdiction over 
            wholesale electric sales in interstate commerce, including 
            sales made entirely intrastate and sales delivered locally to 
            a distribution system.  The PUC has litigated the issue of FIT 
            pricing.  In FERC's ruling found, among other things that the 
            PUC "may take into account obligations imposed by the state 
            that, for example, utilities purchase energy from particular 
            sources of energy or for a long duration." (FERC Order 133 
            FERC  61,059, October 21, 2010, Ordering Paragraph 26).

           4)FIT Procurement Contracts.   Prior legislation (Yee, AB 1969, 
            2006) provided a small renewable generator FITs in the 
            territories of the three largest IOUs and provide a 10, 15, or 
            20-year fixed-price, non-negotiable contract for systems sized 
            up to 1.5 MW.  The PUC has a rulemaking open to implement the 
            terms of SB 32 Negrete McLeod (Chapter 328, Statutes of 2009) 
            and expand the IOU FIT to 3 MWs.  The total program allocation 
            between the three IOUs is approximately 500 MWs.

            On May 24, 2012 the PUC approved a Decision on the SB 32 FIT  
            which provide price adjustments and separates the FIT into 
            three product types: as available, peaking, and non-peaking as 
            available.  Stakeholders in the PUC proceeding requested a 
            set-aside for specific technologies, particularly biogas.  The 
            PUC declined to adopt a technology specific set-aside because 
            the Legislature did not did not provide statutory direction to 
            do so.  However, the three categories established in the PUC 
            do recognize the attributes of the technologies via the three 
            categories of procurement.  Solar is generally a peaking 
            technology, wind is generally an as available technology, and 
            biogas/biomass are generally as available technologies.

            If enacted, the 250 MW authorized by SB 1122 would be in 
            addition to those MW authorized pursuant to SB 32 and would be 
            limited to biogas and biomass technologies.  However, biogas 
            and biomass technologies would also be able to bid into the SB 
            32 FIT.  So there is some question regarding overlap between 
            these two procurement mechanisms.  In addition, the SB 32 FIT 
            is a price-adjusting FIT.  If the PUC adopts a fixed price for 
            the biogas/biomass FIT it will conflict with the price 
            adjustment mechanism and afford developers to 'forum shop' for 
            the best price available.

            It is not clear why these facilities cannot compete for the 








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            currently authorized SB 32 FIT.

           5)Standard Contracts and Ratepayer Incentives?   SB 1122 requires 
            the PUC to coordinate any incentive or subsidy programs for 
            biogas and biomass with the solicitation. 

            It is not clear why these biomass/biogas facilities would need 
            both a standard contract and ratepayer incentives.  The SB 32 
            FIT requires that projects not take ratepayer incentives.

           6)Carve out for bioenergy?  Opponents to this bill oppose a carve 
            out for bioenergy because they prevent fair competition among 
            renewable energy technologies. Supporter point out that 
            bioenergy provides baseload renewable energy and that the 
            program is small and will not impose undue costs on 
            ratepayers. The PUC's report on the RPS shows that there is 
            significant growth in contracts with solar photovoltaic and 
            wind technologies while biogas is at best, tepid growth. 
            Baseload technologies can address issues with intermittency 
            that have been raised about wind (only generates when the wind 
            is blowing) and solar (only generates when the sun shines).

            Bioenergy fuels, particularly biogas, can provide a range of 
            energy services, not limited to generation. Biogas can also be 
            used to power natural gas vehicles and new efforts are 
            underway to provide conditioning that will allow biogas to be 
            safely injected into natural gas pipelines.

           7)Suggested Amendments  .  The author may want to consider the 
            following amendments:

             a)   Amend 399.20 Public Utilities Code to direct the PUC to 
               add a fourth category to the contract categories 
               specifically for bioenergy projects.
             b)   Allocate 250MW of the 750MW allocation in 399.20 to 
               bioenergy projects and provide authority to the PUC to 
               increase the total 750MW cap to meet the 250MW bioenergy 
               goal.
             c)   Provide the PUC discretion to award projects using 
               either the renewable market adjusting tariff (Re-MAT) or a 
               competitive solicitation process and adjust the program 
               based on market response or environment.
             d)   Direct the PUC to develop a streamlined contract with 
               simplified terms and conditions in order to facilitate new 
               market entrants.








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               Provide policy direction to the PUC to encourage programs 
               and services to facilitate the development of in-state 
               biogas and to facilitate the conditioning and upgrading of 
               biogas in order to permit it to be used for a broad range 
               of purposes, including injection into natural gas 
               pipelines, use for onsite power generation, and use at 
               compressed natural gas filling stations for alternative 
               fuel vehicles.

           



          REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          Agricultural Council of California (Ag Council) 
          Agricultural Energy Consumers Association 
          Alliance of Western Milk Producers 
          American Biogas Council
          Association of California Water Agencies (ACWA)
          Biogas & Electric, LLC
          California Association of Sanitation Agencies (CASA)
          California Bioenergy
          California Farm Bureau Federation
          Caterpillar, Inc.
          Clean Power Campaign
          Clean World Partners
          Clear Horizons, LLC
          E3
          Eastern Municipal Water District (EWMD) 
          Electrochaea
          Energy Development Group of Idaho
          Harvest Power
          Hawthorne Power Systems
          Milk Producers Council
          Organic Waste Systems, Inc.
          Peterson Power Systems
          R-Qubed Energy, Inc.
          Sanitation Districts of Los Angeles County
          Solar Turbines Incorporated
          South Coast Air Quality Management District (AQMD)
          SUMA America, Inc.
          Sustainable Conservation








                                                                  SB 1122
                                                                  Page  6

          Tetra Tech, Inc.
           
            Opposition 
           
          Division of Ratepayer Advocates (DRA)
          Pacific Gas and Electric Company (PG&E)
          Southern California Edison (SCE) (unless amended)





           Analysis Prepared by  :    Susan Kateley / U. & C. / (916) 
          319-2083