BILL ANALYSIS                                                                                                                                                                                                    �          1





                SENATE ENERGY, UTILITIES AND COMMUNICATIONS COMMITTEE
                                 ALEX PADILLA, CHAIR
          

          SB 1139 -  Hueso                                  Hearing Date:   
          April 29, 2014             S
          As Amended:         April 21, 2014           FISCAL       B

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                                      DESCRIPTION
           
           Current law  requires investor-owned utilities (IOUs), community  
          choice aggregators (CCAs), and energy service providers (ESPs)  
          (collectively defined as retail sellers), and publicly-owned  
          utilities (POUs), to increase purchases of renewable energy such  
          that at least 33% of total retail sales are procured from  
          renewable energy resources by December 31, 2020. In the interim  
          each entity would be required to procure an average of 20% of  
          renewable energy for the period of January 1, 2011 through  
          December 31, 2013 and 25% by December 31, 2016.  This is known  
          as the Renewables Portfolio Standard (RPS).  (Public Utilities  
          Code � 399.11 et seq.)

           Current law  defines as RPS eligible, electric generation  
          resources from biomass, solar thermal, photovoltaic, wind,  
          geothermal, fuel cells using renewable fuels, small  
          hydroelectric generation of 30 megawatts (MWs) or less, digester  
          gas, landfill gas, ocean wave, ocean thermal, tidal current, and  
          municipal solid waste conversion that uses a non-combustion  
          thermal process to convert solid waste to a clean-burning fuel.   
          (Public Resources Code � 25741)

           Current law  requires 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  
          sized up to three MWs. Statewide participation is capped at 750  
          MWs. (Public Utilities Code �� 399.20, 399.32)

           Current law  requires IOUs to procure at least 250 MWs of  
          renewable generating capacity from bioenergy projects including  











          110 MWs from wastewater treatment, municipal organic waste  
          diversion, food processing and codigestion; 90 MWs from dairy  
          and other agriculture bioenergy; and 50 MWs from generation  
          using byproducts of sustainable forest management. (Public  
          Utilities Code � 399.20) 

           Current law  establishes the Geothermal Resources Development  
          Account into which federal revenues are deposited to fund grants  
          to eligible local jurisdictions and private entities for  
          projects and activities that promote development geothermal  
          energy resources, mitigate any adverse impacts caused by  
          geothermal development, or help local jurisdictions offset the  
          costs of providing public services necessitated by geothermal  
          development. (Public Resources Code � 3800 et seq.)

           This bill  mandates the procurement of 250 MWs of geothermal  
          electric generation no later than 2019, and an additional 250  
          MWs no later than 2024, for a total of 500 MWs, divided  
          proportionately between retail sellers and POUs serving more  
          than 75,000 customers.  Retail sellers and POUs would be  
          required to prepare a procurement plan no later than 2016 for  
          review, approval, modification, or rejection by the California  
          Public Utilities Commission (CPUC) for retail sellers and the  
          California Energy Commission (CEC) for POUs.
                                           
                                     BACKGROUND
           
          What is Geothermal? - Geothermal energy is defined as heat from  
          the Earth. It is a clean, renewable resource that provides  
          energy in the United States and around the world in a variety of  
          applications and resources. Although areas with telltale signs  
          like hot springs are more obvious and are often the first places  
          geothermal resources are used, the heat of the Earth is  
          available everywhere, and the industry reports that it is  
          learning to use it in a broader diversity of circumstances. It  
          is considered a renewable resource because the heat emanating  
          from the interior of the Earth is essentially limitless.  A  
          geothermal system requires heat, permeability, and water. The  
          heat from the Earth's core continuously flows outward. Sometimes  
          the heat, as magma, reaches the surface as lava, but it usually  
          remains below the Earth's crust, heating nearby rock and water -  
          sometimes to levels as hot as 700?F. When water is heated by the  
          Earth's heat, hot water or steam can be trapped in permeable and  
          porous rocks under a layer of impermeable rock and a geothermal  










          reservoir can form. This hot geothermal water can manifest  
          itself on the surface as hot springs or geysers, but most of it  
          stays deep underground, trapped in cracks and porous rock. This  
          natural collection of hot water is called a geothermal  
          reservoir. 

          To develop electricity from geothermal resources, wells are  
          drilled into a geothermal reservoir. The wells bring the  
          geothermal water to the surface, where its heat energy is  
          converted into electricity at a geothermal power plant.  The  
          Geysers in Lake County are typical of geothermal generation and  
          are dry steam power plants where steam is produced directly from  
          the geothermal reservoir to run the turbines that power the  
          generator, and no separation is necessary because wells only  
          produce steam.

          Geothermal Serving California - By the end of 2013, an estimated  
          17,400 MWs of RPS-eligible renewable energy capacity were  
          operating in California of which approximately 15,500 MWs were  
          sold to a utility or the market (wholesale) and an additional  
          1,900 MWs was self-generation.  Of the 15,500 MWs of wholesale  
          generation, 46 projects are geothermal resources and represent  
          2,782 MWs of capacity which is 4.4% of generation capacity.   
          However, geothermal produces approximately 25% of the renewable  
          electricity supplied to California retail customers.  

          The distribution of the 46 online projects which serve  
          California load is:  

                 Imperial County, 20 projects; 705 MWs of capacity;
                 Inyo County, 3 projects; 302 MWs of capacity;
                 Lake County, 6 projects; 418 MWs of capacity;
                 Mono County, 4 projects; 54 MWs of capacity;
                 Sonoma County, 12 projects; 1,238 MWs of capacity; and
                 State of Nevada, 1 project; 65 MWs of capacity.

          Additionally, eight projects for a total of 618 MWs have  
          received environmental permits but are not yet operational.   
          Five projects for a total of 465 MWs have been permitted in  
          Imperial County; one 55 MW project has been permitted in Lake  
          County; and 2 projects for a total of 98 MWs have been permitted  
          in Sonoma County.<1>  There may be additional generation under  
          contract with the utilities the existence of which has yet to be  

          ---------------------------
          <1> CEC January 2014 Renewable Energy Tracking Summary.









          made public.

          Geothermal Ramping Capability - Most of the geothermal  
          generation resources in the state today are baseload resources  
          and lack the ability to ramp up and down to follow the variable  
          demands of the grid.  To facilitate the integration of  
          renewables and meet peak electricity demand, a growing integral  
          part of procurement strategy is increasing flexible capacity  
          that can be called upon in minutes when the clouds blow over or  
          the wind suddenly fades.  This includes fast-start gas plants  
          which can be called upon in less than 30 minutes and demand  
          response.

          According to the Geothermal Resources Council, the technology  
          exists for some new geothermal plants to operate in a flexible  
          mode that can quickly adapt to variability in the power system.  
          Those plants can provide regulation, load following or energy  
          imbalance, spinning reserve, non-spinning reserve, and  
          replacement or supplemental reserve.  Some new geothermal power  
          plants can ramp up and down multiple times per day to a minimum  
          of 10% of nominal power and up to 100% of nominal output power. 

                                       COMMENTS
           
              1.   Author's Purpose  .  California and the Western United  
               States have uniquely high quality solar and geothermal  
               resources.  California utilities are dramatically  
               increasing their utilization of solar resources, but not  
               effectively increasing utilization of geothermal resources.  
               In fact, only a fraction of the geothermal resources that  
               could be supplying California consumers are currently being  
               tapped, and there has been very little increase in  
               geothermal generation capacity during the past decade. For  
               example, the Salton Sea Known Geothermal Resource Area,  
               which provides one of the greatest opportunities for  
               geothermal energy development in the United States, is  
               currently producing less than 500 MWs of power. The  
               remaining untapped generation capacity at this resource is  
               estimated to be at 1,700 MWs. This is a wasted opportunity  
               of such a valuable resource. The long term electric supply  
               portfolio serving California consumers should include much  
               greater reliance on geothermal resources so that we have a  
               balanced portfolio as we move toward a carbon-free  
               generation supply.











              2.   The Big Squeeze  ?  Although geothermal generation  
               currently meets approximately 25% of the state's renewable  
               portfolio, several contracts in the generation portfolios  
               of Southern California Edison and Pacific Gas & Electric  
               will expire in the next five years (San Diego Gas &  
               Electric has no geothermal in its portfolio).  Those  
               generation owners have notified the committee that many of  
               those contracts are at risk and may not be extended.  Other  
               procurement mandates have been made by the Legislature  
               including 250 MWs of bioenergy and 500 MWs of generation  
               sized less than three MWs.  The biomass generators report  
               that many of their long-term contracts are also nearing  
               expiration and they have also been put on notice by the  
               IOUs that they may not see an extension.  Should the  
               Legislature mandate additional procurement when it is not  
               clear if the electricity generation will be needed or if  
               the mandated generation will squeeze out and strand  
               existing, viable generation?   
              3.   Not Without Tryin  g.  According to testimony provided to  
               the Senate Select Committee on California's Energy  
               Independence, the CPUC has approved 340 MWs of  
               power-purchase agreements for geothermal in Imperial  
               County, but all of those projects failed, most because of  
               either permitting issues with the federal government or  
               technology issues.  Additionally, statewide, the CPUC  
               opined that there are ample capacity or baseload resources  
               that run 24/7.  Resources are needed in specific local  
               areas and the state needs more flexible resources that can  
               turn off fairly quickly at the command of the California  
               Independent System Operator.

              4.   Myriad Dynamics Working Against Geothermal  .  There is no  
               easy answer as to why more geothermal generation has not  
               been contracted or developed and there are many dynamics at  
               play.  Consequently, one mandate or one policy change will  
               not guarantee that more generation will succeed where  
               others have not.   Stakeholders active in development of  
               renewable generation have provided the following opinions:  
               significant upfront costs of development to drill for the  
               fuel supply; baseload generation when flexible resources  
               are needed; priority and focus given to developing small  
               scale distributed generation close to load; the need for  
               new transmission from remote areas; failure to account for   










               integration costs of some renewables in competitive  
               procurement causing geothermal to look more expensive when  
               it may not be; property tax exemptions for solar that are  
               not available to other generation resources; and an RPS  
               calculator used by the CPUC in procurement review that  
               disadvantages geothermal.  

              5.   Procurement Mandates Not Without Precedent  .  The  
               Legislature has mandated that the CPUC require the three  
               large IOUs to procure 250 MWs biomass/biogas by 2013 in  
               projects sized no more than three MWs.  The generation was  
               specifically allocated to "dairy and other biogas from  
               wastewater treatment, municipal organic waste diversion,  
               food processing and codigestion 110 MWs; agricultural  
               bioenergy 90 MWs; and bioenergy using byproducts of  
               sustainable forest management, 50 MWs.  These resources are  
               also baseload and could arguably squeeze out other baseload  
               resources.  

               Also a priority for the Governor and the Legislature has  
               been small scale distributed generation which is reflected  
               in mandated feed in tariffs of 500 MWs of generation sized  
               less than three MWs of any renewable type.

              6.   Divvying up the Mandate  .  POUs serve roughly 25% of the  
               state's electric load which would leave them an obligation  
               to buy about 125 MWs of geothermal.  This bill applies to  
               eight POUs in the state - Los Angeles, Sacramento,  
               Imperial, Modesto, Anaheim, Riverside, Turlock and  
               Glendale.  The POUs may not be able to find generation in  
               small increments to satisfy the individual procurement  
               mandate for each of the eight POUs. Although the author  
               includes a provision which allows the POUs to aggregate  
               their procurement mandate, in essence investing in one  
               generation project and splitting the required purchase  
               between the utilities, purchases in small increments  
               between many utilities, or the utilities individually, may  
               be an administrative challenge to manage.  The author and  
               committee may wish to permit additional flexibility and  
               include language which permits compliance with the bill by  
               fewer than eight of the POUs as long as the collective goal  
               is met any one or more of the POUs.

              7.   Approval of POU Procurement Plans  .  This bill calls for  










               POUs to submit geothermal procurement plans to the CEC no  
               later than June 30, 2016.  However, the CEC does not have  
               authority to manage any other POU procurement.  To do so in  
               this bill would be unprecedented.  The California Municipal  
               Utilities Association writes in opposition to this bill  
               that "[n]ever has the CEC had the power to modify or reject  
               adopted energy plans.  This policy would be a first of its  
               kind, and apply only to the procurement of geothermal  
               energy developed after 2015."  The author and committee may  
               wish to strike the language which requires the CEC to  
               review and approve, modify, or reject the POU plans which  
               would leave the POUs with only a reporting requirement to  
               the CEC.

              8.   Funding Salton Sea Restoration  ?  The adoption of this  
               bill is viewed by some supporters as providing a funding  
               stream for the restoration of the Salton Sea.  The Imperial  
               Irrigation District writes in support of this bill that:

                    "?Imperial Irrigation District (IID) and the  
                    County of Imperial have joined together to  
                    advance the Salton Sea Restoration and Renewable  
                    Energy Initiative.  In short, this Initiative  
                    calls for the development of new renewable  
                    energy projects at the Salton Sea that will at  
                    the same time create a sustainable funding  
                    source for air quality management and habitat  
                    restoration projects.  Although this Initiative  
                    may only be a small piece of a larger puzzle, it  
                    represents a collection of new opportunities and  
                    potential partnerships to be explored further."   


               Further questioning of the bill's supporters as to the  
               correlation between geothermal development and Salton Sea  
               restoration reveals an intent to require geothermal  
               developers to pay mitigation fees associated with siting  
               permits to help the region address a $9 billion restoration  
               plan.  This may be a valuable and necessary priority but it  
               would be an inappropriate expense to place on electric  
               ratepayers.  Additionally, the mitigation required by CEQA  
               is for the impacts of the project being sited; not for  
               environmental damage done as a result of prior activities  
               or degradation occurring from external factors long before  










               the project appears.  

               It should also be noted that there is no guarantee or  
               requirement that the procurement mandates of this bill  
               occur in the Imperial Valley.  In fact the two most recent  
               geothermal contracts of which the committee is aware that  
               could be in compliance with this bill's provisions are in  
               Inyo County and the state of Nevada.  Both are due to come  
               online in 2018.  The construction date is not known at this  
               time.

              9.   Not RPS Eligible  .  This bill requires the procurement of  
               generation which is defined as a renewable resource under  
               current law.  However a retail seller or POU would not be  
               permitted to count this generation for purposes of  
               complying with the 33% by 2020 RPS mandate. 

              10.  Legislative Ratemaking  .  Opponents to this bill have  
               opined that the mandated generation would undermine the  
               usual tool utilized for procurement - competitive bidding.   
               They also note the exclusion of any IOU contracts from cost  
               control provisions of the RPS program.  The author  
               responded with amendments that attempt to limit the cost  
               provisions of power purchase agreements and then mandate  
               cost recovery.  The author reports his intent that this  
               provision prevent any excessive cost to the utilities if  
               there is a shortage of competition among geothermal  
               generators and that limiting the amount of the power  
               purchase agreement would prevent geothermal generators from  
               extracting excess profits from the mandate to purchase  
               geothermal generation.  

               These provisions amount to legislative ratemaking and  
               include elements that should be left to the discretion of  
               the contacting parties and the CPUC or POU review of what  
               is just and reasonable for those customers.  To ensure that  
               the CPUC and POUs have the maximum latitude necessary to  
               determine just and reasonable rates and the review of  
               procurement for generation, the author and committee may  
               wish to consider striking this provision.

              11.  Ratepayer Impact  .  Mandating procurement can empower  
               generators to control price when a utility is mandated to  
               purchase since the generator sits in the cat-bird seat.   










               Ratepayers can be disadvantaged by contract costs not  
               competitively bid.  Although the bill calls for  
               procurements to "reasonably minimize costs," the very  
               mandate undermines this goal.  Additionally, the  
               procurement would be specifically exempted from the cost  
               limits established by the CPUC for IOUs under the RPS.

                                       POSITIONS
           
           Sponsor:
           
          Author

           Support:
           
          California Coalition of Utility Employees
          California Latino Water Coalition
          California State Association of Electrical Workers
          California State Pipe Trades Council
          Coachella Valley Economic Partnership
          Desert Valleys Builders Association
          Energy Source
          Environment California
          Greater Palm Springs Convention & Visitors Bureau
          GreenFire Energy Inc.
          Geothermal Energy Association
          Imperial County Board of Supervisors
          Imperial County Building Construction Trades Council
          Imperial Irrigation District
          Indio Chamber of Commerce
          MidAmerican Renewables
          Ormat
          Western States Council of Sheet Metal Workers


           
          Oppose:
           
          California Chamber of Commerce
          California Manufacturers & Technology Association
          California Municipal Utilities Association
          California Wind Energy Association
          M-S-R Public Power Agency
          Office of Ratepayer Advocates










          Pacific Gas and Electric Company
          PacifiCorp, unless amended
          Southern California Edison
          Southern California Public Power Authority
          The Utility Reform Network


          





























          Kellie Smith 
          SB 1139 Analysis
          Hearing Date:  April 29, 2014