BILL ANALYSIS �
AB 1624
Page A
Date of Hearing: April 21, 2014
ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE
Steven Bradford, Chair
AB 1624 (Gordon) - As Amended: April 21, 2014
SUBJECT : Self Generation Incentive Program
SUMMARY : This bill extends authorization for the California
Public Utilities Commission (PUC) to collect funds from
ratepayers for specified technologies to receive incentives
under the Self Generation Incentive Program (SGIP) until 2020
and extend administration of the SGIP until 2021. Specifically,
this bill :
1)Provides an extension of the PUC's authority to collect funds
to be used for the SGIP program until 2020.
2)Provides for an extension of the authority to administer the
SGIP program until 2021.
3)Imposes new eligibility requirements for technologies: capable
of reducing demand from the grid, including peak electric
demand; commercially available; safely uses the existing
transmission and distribution system; reduces greenhouse gas
and improves air quality by reducing criteria air pollutants.
4)Requires the PUC to use specified performance measure when
evaluating the impact and success of SGIP: the amount of
greenhouse gas avoided; reduced energy use for generation
technologies or reduced power use for storage technologies;
the aggregate non-coincident peak demand; the amount of
electricity actually generated by technologies; and the
ability of the technology to improve on-site energy
reliability.
5)Within the performance measures for evaluation of SGIP,
specifies the PUC must establish a capacity factor for
generation technologies and defines how to establish a
capacity factor for energy storage.
6)Specifies that in addition to the performance measures for
evaluating SGIP, the PUC must evaluate the SGIP's progress
toward reducing regulatory barriers to distributed energy
resources, including frequency regulation, voltage support,
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demand reduction, peak shaving, ramp rate control, and other
wholesale ancillary and grid reliability services.
EXISTING LAW
a)Specifies the intent that SGIP increase deployment of
distributed generation and energy storage systems to
facilitate the integration of those resources into the
electrical grid, improve efficiency and reliability of the
distribution and transmission system, and reduce emissions of
greenhouse gases, peak demand, and ratepayer costs. (Public
Utilities Code 379.6(a))
b)Specifies the intent of the Legislature that SGIP funds
provide an equitable distribution of the costs and benefits of
the program. (Public Utilities Code 379.6(a))
c)Authorizes the PUC, to authorize the annual collection of not
more than the amount authorized for SGIP program in the 2008
calendar year, through December 31, 2014. (Public Utilities
Code 379.6 (a))
d)Requires the PUC t to require electrical corporations to
administer the SGIP until January 1, 2016. (Public Utilities
Code 379.6(a))
e)Requires the PUC to provide repayment of all unallocated funds
collected for the SGIP on January 1, 2016, to reduce ratepayer
costs. (Public Utilities Code 379.6(a))
f)Restricts eligibility for SGIP incentives to those distributed
energy resources that the PUC, in consultation with the
California Air Resources Board (ARB), determines will achieve
reductions in emissions of greenhouse gases pursuant to the
California Global Warming Solutions Act of 2006. (Public
Utilities Code 379.6(b))
g)Specifies emissions criteria for SGIP incentives for
combustion technologies and combined heat and power
technologies. (Public Utilities Code 379.6(c))
h)Specifies certain conditions for projects that operate solely
on waste gas which, if not met, exclude them from receiving
SGIP incentives. (Public Utilities Code 379.6(c)(4))
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i)Provides that the PUC may, in administering SGIP, adjust the
amount of rebates and evaluate other public policy interests,
including, but not limited to, ratepayers, energy efficiency,
peak load reduction, load management, and environmental
interests. (Public Utilities Code 379.6(e))
j)Requires the PUC to ensure that distributed generation
resources are made available in the program for all
ratepayers. (Public Utilities Code 379.6(f))
aa)Requires the PUC to provide an additional incentive of 20
percent from existing SGIP funds for the installation of
eligible distributed generation resources from a California
supplier. (Public Utilities Code 379.6(g))
FISCAL EFFECT : Unknown
COMMENTS :
1)Author's Statement. SGIP, one of California's first programs
to provide incentives for the deployment of distributed
generation and energy storage (collectively, distributed
energy resources or DER), creates an incentive for residential
and commercial customers to reduce the upfront costs of onsite
DER. The program assists a wide swath of ratepayers - from
homeowners, multi-unit housing to large commercial facilities.
SGIP complements the Renewable Portfolio Standard (RPS) and
the California Solar Initiative (CSI) and will help
Investor-Owned Utilities comply with the CPUC's Energy Storage
Decision. SGIP also gives customers a choice about how to meet
their electricity needs with secure, clean DER.
AB 1624 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. Additionally, a variety
of performance measures/metrics will be built into the
program, through AB 1624, to ensure that California's utility
ratepayers are being benefitted by the continuation of the
SGIP.
2)Program History . On August 31, 2000, the final day of the
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1999-2000 Legislative Session, AB 970 (Ducheny) was gutted and
amended. The bill included a variety of provisions quickly
cobbled together in an effort to respond to the emerging
energy crisis in San Diego, where San Diego Gas and Electric
was the first utility to expose its customers to unfrozen
rates under California's ill-fated experiment with electric
industry restructuring. Because the crisis was misunderstood
at the time to be the result of a physical supply shortage, AB
970's primary focus was to increase electric generation
supply, and most of the bill's provisions were related to
expediting the siting of power plants.
A single sentence in AB 970 required the Public Utilities
Commission (PUC) to adopt "(d)ifferential incentives for
renewable or super clean distributed generation resources"
within 180 days of the effective date of the bill. Aside from
the objective to "reduce demand for electricity and reduce
load during peak demand periods," no further definitions or
instructions were included in AB 970. The bill required the
"reasonable costs" of the PUC's action to be included in the
distribution revenue requirement of PUC-regulated utilities.
This provision was not mentioned in the Senate or Assembly
bill analyses.
Pursuant to this provision of AB 970, the PUC established the
SGIP in 2001, offering customer rebates for renewable and
"super clean" distributed generation resources. SGIP has been
extended and/or modified by at least six bills since then.
Over the last 13 years, the SGIP has offered rebates for
installation of solar, wind, fuel cell, and certain renewable
and fossil fuel combustion resources meeting specified
emissions and efficiency standards.
A 2005 report commissioned by the PUC to study the
cost-effectiveness of SGIP concluded that the program is
marginally cost-effective for participants (i.e., recipients
of funding), but is not cost-effective to non-participants
(i.e., ratepayers who pay for it). Because SGIP is funded
from distribution rates, its costs are disproportionately
borne by residential ratepayers. However, historically only
larger projects have been eligible for SGIP, so residential
ratepayers haven't been able to access the incentives.
With the enactment of the California Solar Initiative (CSI)
through PUC order and SB 1 Murray (Chapter 132, Statutes of
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2006), photovoltaic (PV) systems were no longer eligible for
SGIP incentives. PV incentives were provided instead under
the CSI. . In 2006, AB 2778 Lieber (Chapter 617, Statutes of
2006) extended SGIP for wind and fuel cells until 2012, but
excluded combustion projects.
In 2009, SB 412 Kehoe (Chapter 182, Statutes of 2009) extended
SGIP collection through 2011, modified eligibility to include
fossil fuel projects that reduce greenhouse gas (GHG)
emissions, and required the PUC to administer the program
until 2016 (the additional time was allotted to spend a $200+
million surplus accumulated from prior years).
A 2010 PUC investigation<1> on the performance of combined
heat and power (CHP) found that CHP projects experienced
increased time spent not operating, reductions in output when
operating, and decreases in electrical efficiency and thermal
heat recovery over time. The investigation further found that
unexpected levels of maintenance and economic complexity have
dampened participant satisfaction.
In response to a December 22, 2010 request from SGIP
administrators, the program was suspended by a PUC ruling
issued February 10, 2011, which froze applications received on
or after January 1, 2011. The reason for the suspension was
that a rush of awards and applications, mostly from a single
vendor, had nearly exhausted both the current budget and the
accumulated surplus, leaving less funding than expected for
future awards under SB 412. Later in 2011, the PUC adopted a
decision implementing SB 412 and reinstated the program. At
the same time, the PUC made advanced energy storage systems
(AES) eligible for SGIP incentives.
Notwithstanding the issues with the program and the SB 412
agreement to sunset SGIP in 2016, in 2011, AB 1150 V. Manuel
P�rez (Chapter 310, Statutes of 2011) allowed the PUC to fund
SGIP for an additional three years. Under AB 1150, the PUC
may authorize the utilities to collect up to $83 million per
year from their customers through December 31, 2014. However,
AB 1150 maintained the January 1, 2016 sunset on the program,
at which time the PUC must provide repayment of all
--------------------------
<1> SGIP Incentive Program, Combined Heat and Power Performance
Investigation http://www.cpuc.ca.gov/NR/rdonlyres/594FEE2F-B37A-4F
9D-B04A-B38A4DFBF689/0/SGIP_CHP_Performance_Investigation_FINAL_2
010_04_01.pdf , April 2010,
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unallocated funds to reduce ratepayer costs.
3)2012 Program Evaluation. The most recent evaluation of SGIP,
"2012 SGIP Impact Evaluation and Program Outlook,"<2> was
prepared by Itron under contract and published by the PUC on
February 7, 2014. Among the report's key findings are:
SGIP spent an average of $311 per metric ton of CO2
reductions through 2012.
Ratepayers paid $33 million in incentives for $7 million
in benefits (avoided costs) in 2012.
Of the completed SGIP projects (excluding PV projects),
o 52% of the project capacity remains
operational.
o 8% of the project capacity has been
decommissioned.
o 14% of the project capacity is offline.
o 26% of the project capacity has no information
available on the condition of the project.
Assuming build-out of the queue of pending SGIP projects
and continuation of the current program guidelines and
rules, GHG emission reductions and peak demand reductions
will grow.
There is insufficient independent information to
quantify market transformation impacts.
1)Projects receiving incentives under the newer, performance
based SGIP . The 2012 Program evaluation could not provide
insights into how projects were performing under revisions the
PUC made to the program to make it "performance based" in
order to address concerns expressed about less than stellar
performance reports in prior evaluations. In response to a
data request from the Natural Resources and Utilities &
Commerce Committees, the PUC provided supplemental information
on how the program is faring under its new performance based
criteria. The PUC reports that:
Greenhouse Gas Reduction Costs . Current estimates, from
the available data on funded projects, indicate a reduction
in total cost for SGIP technologies from an average of $311
per metric ton of CO2 for projects installed before
D.11-09-015 to an average of $232 per metric ton of CO2 for
--------------------------
<2> 2012 SGIP Impact Evaluation and Program Outlook,
http://www.cpuc.ca.gov/NR/rdonlyres/25A04DD8-56B0-40BB-8891-A3E29
B790551/0/SGIP2012ImpactReport_20140206.pdf
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projects installed after D.11-09-015.
Peak Demand Savings . There is not currently adequate
data available to accurately calculate or predict peak
demand savings for projects funded and in the queue since
D.11-09-015. The current lack of data can be attributed to
two factors:
1. There are simply too few systems installed since
D.11-09-015 that have been operating long enough to
provide a sufficient data set to accurately report or
predict peak demand savings.<3>
2. There are currently data transfer issues between the
SGIP database administrator and the program
administrators (PA). The database administrator is in the
process of adjusting the database so that it may receive
all data for all projects. As the database administrator
and the PAs were not anticipating the need to analyze
this data until June 2014, the database infrastructure to
receive certain data necessary for this analysis is not
in place at this time.
The PUC reports that the data transfer issue will be
resolved, and additional data will be available for the
2013 Annual Impact Assessment report and the SGIP
Cost-Effectiveness Analysis report, both expected later
this year.
1)SGIP Market Concentration. In testimony provided at the joint
hearing held by this committee with the Assembly Committee on
Natural Resources in March 2014, The Utility Reform Network
(TURN) stated that SGIP funds the most expensive technologies
(fuel cells and batteries, which achieve lower greenhouse gas
reductions and do not assist with current electricity system
needs for flexibility and ramping. They pointed out that there
is little evidence of decreasing costs for the technologies
receiving SGIP incentives and question the value to electric
ratepayers providing subsidies to Bloom Energy, GE, and Tesla.
---------------------------
<3> Itron notes that actual savings from projects installed
before D.11-09-015 are not suitable for estimation purposes
given that the performance-based incentive (PBI) requirements
implemented by D.11-0-015 are expected to result in increased
savings.
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According to TURN, between 2007 and the 3rd Quarter of 2013, 5
companies received the vast majority of the SGIP incentives:
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-------------------------------------------------------------
|Manufacturer | Incentives | Pending | Total |
| | (2007-3Q2013) | Incentive | |
| | | Requests | |
|--------------------+----------------+------------+----------|
|Bloom Energy | $170,068,200|$116,676,100|$286,744,3|
|Corporation | | | 00 |
|--------------------+----------------+------------+----------|
|Fuel Cell Energy | $43,875,000| *|$43,875,00|
| | | | 0|
|--------------------+----------------+------------+----------|
|UTC Power / | $16,502,000| *|$16,502,00|
|ClearEdge | | | 0|
|--------------------+----------------+------------+----------|
|GE Energy | $10,801,000| $34,723,660|$45,524,66|
| | | | 0 |
|--------------------+----------------+------------+----------|
|Tesla | N/A| $26,184,124|$26,184,12|
| | | | 4|
|--------------------+----------------+------------+----------|
|Stem Inc. | *| $9,362,448|$9,362,448|
| | | | |
|--------------------+----------------+------------+----------|
|Caterpillar | *| $6,293,000|$6,293,000|
| | | | |
|--------------------+----------------+------------+----------|
|Mitsubishi Power | $5,250,000| *|$5,250,000|
|Systems | | | |
|--------------------+----------------+------------+----------|
|All Others | $18,912,476| $62,667,184|$81,579,66|
| | | | 0 |
|--------------------+----------------+------------+----------|
|Total | $265,408,676|$255,906,516|$521,315,1|
| | | |92 |
-------------------------------------------------------------
These companies may have received incentives that are in
the "All Other" category but were not ranked as high for
the period.
1)Can SGIP provide Market Transformation? Although "market
transformation" is not mentioned in the SGIP statute, much
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less defined, the PUC states that it is one of the four
principal goals of the current SGIP program. The most
specific description of SGIP market transformation appears in
the PUC initial SGIP staff proposal,<4> which states the
following:
"SGIP should complement the structure of and be coordinated
with existing ratepayer supported programs, especially the
California Solar Initiative, which is aimed at transforming
the market for renewable distributed generation by driving
down prices and increasing performance of (distributed
energy resources)."
and:
"Market Transformation Objectives - Technologies that may
not be cost-effective today, but have the potential to be
cost-effective in the near future, can be supported along
the path toward cost-effectiveness through incentives. By
facilitating greater deployment of these technologies, SGIP
may help these technologies achieve economies-of-scale,
which can drive down costs. However, SGIP is likely to only
be a small part of the global market for these
technologies, and [PUC] staff does not expect that the
California market can play a significant (or measurable)
role in market transformation."
If the California market can play a significant or
measureable role in market transformation through the SGIP
program then it should not be a goal of the program.
2)Time for new focus for SGIP? AB 1624 provides a new focus on
technologies that receive SGIP incentives and also provides
stricter performance and evaluation criteria. By doing so, AB
1824 provides some level of assurance that if it is enacted,
the next time a reauthorization is requested, the Legislature
will be able to gauge the extent to which the program has made
improvements to address the statutory goals.
3)Time for a new funding source for SGIP? The PUC is currently
authorized to collect no more than $83 million annually to
support SGIP and to provide for repayment of unallocated funds
---------------------------
<4> SGIP Staff Proposal,
http://docs.cpuc.ca.gov/PublishedDocs/EFILE/RULINGS/124214.PDF ,
page 20, September 2010
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when the program terminates in 2016. California ratepayers
have contributed approximately $925 million in funds to
provide SGIP incentives through 2013. Adding to that, the
costs are disproportionately borne by residential ratepayers
even though residential customers have not participants in
this program. With SGIP's focus on greenhouse gas emission
reductions and very little evidence that there can be a
ratepayer benefit, it may be worth considering using a
different source to fund SGIP.
In 2012, the Legislature approved SB 1018 Committee on Budget
and Fiscal Review (Chapter 39, Statutes of 2012) which
included a provision that allows the PUC to allocate up to 15
percent of the revenues received as a result of the direct
allocation of greenhouse gas allowances to electrical
corporations to be used for clean energy and energy efficiency
programs that are not otherwise funded by another funding
source. (Public Utilities Code 748.5(c))
The PUC decided not to make this allocation in its Decision
12-12-033 and instead increase the amount of fund available to
be returned to customers of the electrical corporations.
According to the PUC, in total, the five utilities (PG&E, SCE,
SDG&E, PacifiCorp and Liberty) will return $1.2 billion in
allowance revenue to customers in 2014, while they introduce
approximately $840 million in Cap and Trade costs over this
same time. In its decision, the PUC encouraged parties to
continue to present proposals for energy efficiency and clean
energy projects to be funded with allowance revenue.
The author may wish to consider an amendment that will replace
the ratepayer funds used to support SGIP with the funds that
were authorized pursuant to section 748.5(c) of the Public
Utilities Code.
While this new source of funding is helpful to extending the
program, it should also be clear that SGIP must not be treated
as a never-ending program. Declining incentives have helped
industry to make progress toward commercialization without
subsidy (for example, the California Solar Initiative's
10-year program with a 7% annual decline in incentives. SGIP
was established in 2000 and began as a program in 2001. AB
1624 calls for a 6-year extension, however, it provides
incentives to a wider variety of technologies.
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In addition, the author may wish to reduce the total amount
authorized in the annual allocation by 10 percent per year and
direct the PUC to re-prioritize SGIP funding, beginning in
2018 to reduce eligibility, reduce the incentive amount, or
both so that SGIP is more likely to fund those technologies
that will improve their ability to reduce greenhouse gas
emission costs and produce electricity at a time and in a
manner that reduces peak demand for electricity. For example,
total amount of SGIP incentives available in 2015 would be $83
million, in 2016 it will be reduced to $74.7 million, in 2017
it will be reduced to $66.4 million, and so on.
4)Energy storage. Energy storage is not a generation technology.
Thus its benefits are limited to when it can offset peak
electricity demand, reduce greenhouse gas emissions, and
contribute to reducing peak demand or grid reliability when
needed and available. Currently energy storage receives SGIP
incentives without a specified level of support. The PUC
allows SGIP incentives for "advanced energy storage," however,
the PUC has not established a definition of what types of
technologies are advanced, consistent with the SGIP goals
specified in statute.
In order to ensure that SGIP funds are used for advanced
energy storage, the author may wish to consider directing the
PUC to create an advanced energy storage component within the
SGIP with a separate budget within the annual allocation and
direct the PUC to define "advanced energy storage" in an open
or new proceeding.
In addition, AB 1624 proposes a definition of capacity factor
for energy storage systems eligible for incentives that is
more consistent with the benefits of energy storage. The
author may wish to modify the definition to reference advanced
energy storage systems and modify the language so that the
ratio of the number of hours an advanced energy storage system
is available for capacity applications is based on the number
of hours between Monday and Friday, excluding holidays, during
each electrical corporation's peak electricity demand periods.
This will ensure that the capacity factor for advanced energy
storage is based on the benefits of when storage is available
to offset peak electricity demand.
5)Reducing barriers to the adoption of distributed energy
resources. AB 1624 adds criteria for the PUC to use when
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evaluating SGIP related to measuring the programs progress
toward reducing barriers to the adoption of distributed energy
resources, including, but not limited to, interconnection
costs and the length of time to complete interconnection.
While these are important issues, they are being addressed in
other venues, such as the PUC's Rule 21 Working Group. The
2012 SGIP Evaluation report did not mention interconnection as
a barrier in this program.
The author may wish to strike this new responsibility so that
the scope of the SGIP program is not expanded.
6)Support and Opposition.
Supporters request extension and emphasize the program's
benefits for reducing greenhouse gas emissions.
Sempra supports AB 1624 and suggests amendments to direct the
incentives directly to the end use customer, eliminate
incentives for battery energy storage because other incentives
are already available, and that SGIP funding be reduced by 20%
each year over a 5-year period to help accelerate the market
for these technologies.
The contract administrator for SGIP, the California Center for
Sustainable Energy (CCSE), also supports extending SGIP.
TURN opposes extension of SGIP because it would extend a very
high subsidy for private commercial customers and a handful of
manufacturers, and is an ineffective and costly means to
reduce carbon emissions. TURN does not oppose allowing an
extension to expend funds already collected.
7)Related Legislation.
AB 1499 (Skinner, 2014) would extend SGIP for 3 years.
8)Suggested amendments.
379.6. (a) (1) It is the intent of the Legislature that the
self-generation incentive program increase deployment of
distributed generation and energy storage systems to
facilitate the integration of those resources into the
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electrical grid, improve efficiency and reliability of the
distribution and transmission system, and reduce emissions of
greenhouse gases, peak demand, and ratepayer costs. It is the
further intent of the Legislature that the commission, in
future proceedings, provide for an equitable distribution of
the costs and benefits of the program.
(2) The commission, in consultation with the Energy
Commission, may authorize the annual collection of not more
than the amount authorized for the self-generation incentive
program in the 2008 calendar year, through December 31, 2020.
The commission shall require the administration of the program
for distributed energy resources originally established
pursuant to Chapter 329 of the Statutes of 2000 through and
including December 31, 2021 2014 . Beginning January 1, 2015,
the commission shall allocate up to $83 million from the funds
allocated for clean energy programs pursuant to section 748.5
(c) of the Public Resources Code. Beginning on January 1, 2016
and each year thereafter until December 21, 2021, the
commission shall reduce the amount allocated by $8.3 million .
On January 1, 2022, the commission shall provide repayment of
all unallocated funds collected pursuant to this section to
reduce ratepayer costs.
(f) In administering the self-generation incentive program,
the commission shall do both of the following:
(1) Determine a capacity factor for each distributed
generation system in the program.
(2) Define eligibility of advanced energy storage based on
characteristics that have electricity and greenhouse
emission benefits and dedicate allocate a portion of the
SGIP annual budget specifically to advanced energy storage
technologies based on their potential benefits for reducing
greenhouse gas emissions and reducing peak electricity
demand.
(3) Define a capacity factor for advanced energy storage
systems in the program as the ratio of the total hours the
advanced energy storage system is used for charging and
discharging throughout the year, over the 10 year useful
life of the advanced energy storage system , including the
hours when the energy storage system is available for
capacity applications even if not actively charging or
discharging, to the total number of peak hours in a the
year. , Monday through Friday, excluding holidays.
(k) (1) The commission shall evaluate the overall success
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and impact of the self-generation incentive program based
on the following performance measures:
(A) The amount of reductions of emission of greenhouse
gases.
(B) The amount of reductions of emissions of criteria air
pollutants measured in terms of avoided emissions and
reductions of criteria air pollutants represented by
emission credits secured for project approval.
(C) The amount of energy reductions measured in energy
value.
(D) The amount of reductions of aggregate noncoincident
customer peak demand.
(E) The ratio of the electricity generated by distributed
energy resource projects receiving incentives from the
program to the electricity capable of being produced by the
distributed energy resources projects, commonly known as a
capacity factor.
(F) The value to the electrical transmission and
distribution system measured in avoided costs of
transmission and distribution upgrades and replacement.
(G) The ability to improve onsite electricity reliability
as compared to onsite electricity reliability before the
SGIP technology was placed in service.
(2) In addition to evaluating the program based on the
performance measures specified in paragraph (1), the
commission shall also evaluate both of the following:
(A) The program's progress toward reducing barriers to the
adoption of distributed energy resources, including, but
not limited to, interconnection costs and the length of
time to complete interconnection.
(B) The program's effectiveness in providing frequency
regulations, voltage support, demand reduction, peak
shaving, ramp rate control, and other wholesale ancillary
and grid reliability services.
New section (l): after section (k):
To ensure that the self-generation incentive program is
more likely to fund those technologies that will improve in
their ability to reduce greenhouse gas emission reduction
costs and produce electricity at a time and in a manner
that reduces the peak demand for electricity, beginning in
March 2017 and each year thereafter, as long as the SGIP
program is providing incentives, the commission shall
review the level of incentives and the cost of the
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technologies that are receiving incentives and (1) allow
incentive eligibility for new technologies or (2) remove
incentive eligibility or reduce incentives for technologies
that have received incentives but have not reduced
greenhouse gas emission reduction costs or provided a
ratepayer benefit.
REGISTERED SUPPORT / OPPOSITION :
Support
Advanced Energy Economy
Agricultural Energy Consumers Association (AECA)
American Vanadium Corp.
Association of California Water Agencies (ACWA)
AT&T
Bergey Wind Power
Bioenergy Association of California
Bloom Energy
Bosch Energy Storage
California Association of Sanitation Agencies (CASA)
California Energy Storage Alliance (CESA)
California Manufacturers & Technology Association (CMTA)
California Solar Energy Industry Association (CalSEIA)
California State University
Capstone Turbine Corporation
ClearEdge Power
CODA Energy
Direct Access Customer Coalition
EDF Renewable Development, Inc.
EnerVault
Environmental Defense Fund
EtaGen
EV Grid
Facebook
Fuel Cell Energy (FCE)
Green Charge Networks
Imergy Power Systems
Inland Empire Utilities Agency (IEUA)
LightSail Energy
Outback Power Technologies
Parker Hannifin's Global Energy Grid Tie
Powertree Services, Inc.
Primus Power
Providence Health & Services
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Rosendin Electric
San Diego Gas and Electric (SDG&E) (if amended)
Seeo, Inc.
Solar Energy Industries Association (SEIA)
SolarCity
Southern California Gas Company (SoCalGas) (if amended)
Stem, Inc.
TechNet
Yahoo!
Opposition
The Utility Reform Network (TURN)
Analysis Prepared by : Susan Kateley / U. & C. / (916)
319-2083