HomeMy WebLinkAbout13-Discuss CEC Changes to the Renewable Portfolio Standard (RPS) Definitionr TRUC EE DONNE
Public Utility District
WORKSHOP
To: Board of Directors
From: Stephen Hollabaugh
Date: September 18, 2013
Subject: Discuss CEC Changes to the Renewable Portfolio Standard (RPS)
Definition
1. WHY THIS MATTER IS BEFORE THE BOARD
This workshop is intended to shed some light on the Renewable Portfolio Standard
(RPS) and its changes made to it since its inception. Also the Power Content Label
(PCL) can sometimes be confused with the RPS. Each of these are calculated
differently.
2. HISTORY
The original California renewable portfolio standard (RPS), adopted in September
2002 by senate bill 1078 (SB1078), required 20% of the generation be sourced from
eligible renewables by 2017. This requirement was accelerated to 20 % by 2010 in
September 2006 when the legislature passed SB 107. Local publically owned utilities
(POU's) are exempt from the RPS requirements, although municipal utilities must
develop their own RPS policies. In 2011, the Legislature, modified the state's RPS
program and sets forth new RPS requirements applicable to POUs. TDPUD, as a
POU, is covered under the new legislation. Pursuant to Public Utilities Code §
399.30(a), each POU must adopt and implement a renewable energy resources
procurement plan (referred to herein as the "RPS Procurement Plan"). In addition
POUs must have adopted and implemented a separate program for the enforcement
of the RPS Procurement Plan by January 1, 2012.
• The Board approved the District's first RPS in 2004 by resolution 2004-10. The
Board defined qualifying resources as non -fossil fuel generating resources,
including all hydroelectric resources.
• The Board replaced and updated its RPS in March 2007 and set a minimum
target of 21 % renewables by 2010. The qualifying resources remained the
same and included all hydro electric resources. The RPS was calculated by
summing the MWh of resources as defined by the Board and dividing that by
the total MWh purchased by the District in that year. This total MWh purchased
included transmission and distribution losses.
• The Board replaced its RPS in December 2011 for compliance with state law. In
order to fulfill unmet long-term generation resource needs, TDPUD adopted and
implemented this RPS Procurement Plan that requires the utility to procure a
minimum quantity of electricity products from eligible renewable energy
resources, including renewable energy credits, as a specified percentage of
TDPUD's total kilowatt hours sold to its retail end -use customers. This was the
first time that the denominator was defined as "total kilowatt hours sold to its
retail end -use customers". Senate Bill (SB) 1x2 contained language that was
specific to TDPUD. The provisions of Public Utilities Code section 399.30(i)
apply to the TRUCKEE DONNER PUBLIC UTILITY DISTRICT since the
DISTRICT was in existence before January 1, 2009, provides retail electric
service to 13,167 customer accounts as of December 2011, and is
interconnected to a balancing authority that is located outside the state of
California (NV Energy) but within the Western Electric Coordinating Council.
A. Eligible renewable energy resources (consistent with § 399.30(i)):
includes a facility that is located outside California that is connected to
the WECC transmission system.
• The Board also approved a RPS Enforcement Program in 2011. This program
included an annual review of the Truckee Donner RPS Procurement Plan to
determine its compliance.
The CEC has been working on the CEC Guidebook for RPS Eligibility for years. This
guidebook was formally adopted by the Energy Commission on April 21, 2004 and
subsequently revised on May 19, 2004, August 11, 2004, May 21, 2005, April 26,
2006, March 14, 2007, December 19, 2007, December 15, 2010, May 9, 2012, August
9, 2012 and April 30, 2013 with the Seventh edition.
3. NEW INFORMATION
The POU enforcement regulations started in 2011. The formal rulemaking began in
March 2013. The regulations were approved by the Energy Commission on June 12,
2013 and by OAL on August 28, 2013. These RPS enforcement regulations will
become effective on October 1, 2013. These regulations apply retroactively back to
2011. NCPA has been working with the Energy Commission to revise the reporting
tools and the portion of law that applies to Truckee Donner PUD directly.
Within the RPS enforcement regulations, they for the first time define for a specific
purpose the term "Retail Sales". Retail sales are used in the denominator to calculate
the percent (%) RPS for a POU. Section 3201 (bb) of the CEC regulations define
retail sales as: "Sale of electricity by a PUD to end -use -customers and their tenants,
measured in MWh. This does not include energy consumption by a POU, electricity
used by a POU for water pumping, or electricity produced for onsite consumption (self -
generation)."
This definition changes what the District has done in the past. The District over time
has used three different methods to calculate RPS%. Each of these methods were
correct at the time they were used. These methods are:
• "Old RPS% Board Defined" - MWh of Board defined renewables that included
large hydro divided by all retail sales
• "Old RPS V - MWh of eligible renewables divided by all retail sales
• "New RPS V - MWh of eligible renewables divided by CEC section 3201 (bb)
definition of retail sales
The table below shows history of RPS% and normalizes prior years using the CEC
definition of retail sales.
It also shows the progress the District has made over the years concerning RPS.
Changing RPS Definition by CEC
TDPUD Use + CEC Definition of Sales
Year Retail Sales (MWh) Water Pumping Retail Sales (MWh)
2012
146,014
8,883
137,132
2011
149,978
8,340
141,638
2010
147,647
9,402
138,244
2009
146,875
10,539
136,336
2008
148,305
11,003
137,302
2007
147,091
12,107
134,984
2006
144,269
11,772
132,497
2005
136,339
11,491
124,848
2004
135,253
12,261
122,992
2003
126,580
11,137
115,443
2002
126,879
11,064
115,814
2001
122,482
9,334
113,149
OLD RPS% RPS% RPS%
Board Defined OLD NEW
39.4%
42.0%
33.0%
35.0%
22.3%
23.8%
34.2%
27.7%
29.8%
24.4%
17.2%
18.6%
8.9%
0.4%
0.4%
20.7%
0.0%
9.9%
0.0%
0.05%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
OLD RPS% Board Defined includes Large Hydro
RPS %OLD uses Al Retail Sales as demonimator
RPS% NEW uses Section 3201(bb) of the CEC Regulations as calculation
4. FISCAL IMPACT
There is no direct fiscal impact associated with this item.
5. RECOMMENDATION
Receive this report and provide comments.
a�
Stephen Hollabaugh Michael D. Holley
Assistant General Manager General Manager