HomeMy WebLinkAbout8-1,Procurement Plan-Draft Update-red lineAttachment 1
Truckee Donner Public Utility District
Renewable Energy Resources Procurement Plan
Per Senate Bill 1x 2
Approved by the Truckee Donner Public Utility District Board of Directors: ?(, X x, 2013De&en -? V41 Formatted: Highlight
INTRODUCTION
This document presents the Renewable Energy Resources Procurement Plan of the Truckee
Donner Public Utility District (Truckee Donner) as required for compliance with Senate Bill
(SB) 1X 2. This legislation, which was enacted in the 2011-2012 First Extraordinary Session of
the Legislature, modifies the state's renewable portfolio standard (RPS) program and sets forth
new RPS requirements applicable to publicly owned utilities (POUs). Truckee Donner, 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 to the development of an RPS Procurement
Plan, SB 1X 2 requires POUs to adopt and implement a separate program for the enforcement of
the RPS Procurement Plan by January 1, 2012.1 Truckee Donner's enforcement program is not
addressed in this document, but rather, in a separate report.
Truckee Donner's RPS Procurement Plan, as reflected in Sections 1-13 below consists of: (1)
plan elements that are directly mandated by the legislation; (2) measures that address each of the
optional provisions set forth in §399.30(d) and sections 3206 of the RPS Re l�u ation; and (3)
RPS reporting provisions. Where appropriate, this RPS Procurement Plan includes section
citations to the legislation Public Utilities Code (PUC) sections 399.11, et seq, as last revised in
2012.
Purpose (§ 399.30(a))
In order to fulfill unmet long-term generation resource needs, Truckee Donner adopts and
implements 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 Truckee Donner's total kilowatt
hours sold to its retail end -use customers, each compliance period, to achieve the targets
specified in SB 1X 2.
2. Compliance Periods (§ 399.30(b))
A. Compliance Period 1: January 1, 2011, to December 31, 2013, inclusive.
1 Pursuant to § 399.30(e), POUs must adopt a "program for enforcement" of the RPS Procurement Plan on or before
January 1, 2012, at a publicly noticed meeting with not less than 30 days prior notice given to the public.
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Compliance Period 2: January 1, 2014, to December 31, 2016, inclusive.
C. Compliance Period 3: January 1, 2017, to December 31, 2020, inclusive.
D. Annual Compliance Periods: Annually after 2020.
Procurement Targets of Renewable Energv Resources for Each Compliance Period
(§§ 399.30(c)(1) and (2))
A. During Compliance Period 1, January 1, 2011 to December 31, 2013, Truckee
Donner shall procure renewable energy resources equivalent to an average of at
least twenty percent (20%) of retail sales, applying the following formula:
EP 2011 + EP 2012 + EP 2013 > .20
RS 2011 + RS 2ol2+ RS 2013
Where:
R% = total retail sales made by POU for the specified year x
EPx = electricity products retired for the specified year x; this may include excess
procurement and historic carryover that the POU has chosen to apply to the
compliance period containing year x
- Retail sales = section 3201(bb) of the RPS regulations define as: "Sale of
electricity y a POU 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)."
By the end of Compliance Period 2, December 31, 2016, Truckee Donner shall
procure renewable energy resources equivalent to at least twenty-five percent
(25%) of retail sales.- , applying the following formula:
EP 20l4 + EP2015 + EP2016 > 0.20 RS2014) + 0.20 (RS2oj5 + 0.25 (RS2oi6)
C. By the end of Compliance Period 3, December 31, 2020, Truckee Donner shall
procure renewable energy resources equivalent to at least thirty-three percent
(33%) of retail sales. During the intervening years of Compliance Period 3,
Truckee Donner shall increase procurement annually to reflect an imputed 2020
compliance obligation expressed as:
EP 017 + EP2018 + EP2019 + EP2020)
> 0.27 RS2017) + (0.29 (RS2ols) + 0.31 (RS2019) + 0.33 (RS2o2o)
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D. Commencing on December 31, 2021, and annually thereafter, Truckee Donner
shall procure renewable energy resources equivalent to at least thirty-three percent
(33%) of retail sales.
The procurement targets listed above are minimum requirements. The Board of Directors
may determine that a higher percentage of renewable energy resources is appropriate in
any given compliance period.
The method used to determine the actual renewable energy resource percentage achieved
for a given calendar year shall be to: (i) sum the total metered generation from each of
Truckee Donner's eligible renewable resources and qualifying purchases in Megawatt
hours (MWh) during the preceding calendar year, (ii) subtract sales, if any, of eligible
renewable resources during the same time period, and (iii) divide the result by the total
energy sold to Truckee Donner's retail end -use customers (in MWh) in the same time
period.
4. Reasonable Progress Towards Meeting Compliance Period Targets During
Intervening Years (§§ 399.30(c)(1) and (2))
A. By December 31, 2014, Truckee Donner shall demonstrate that it is making
reasonable progress towards ensuring that it shall meet the twenty-five percent
(25%) RPS target by 2016.
B. By December 31, 2015, Truckee Donner shall demonstrate that it is making
reasonable progress towards ensuring that it shall meet the twenty-five percent
(25%) RPS target by 2016.
C. By December 31, 2017, Truckee Donner shall demonstrate that it is making
reasonable progress towards ensuring that it shall meet the thirty-three percent
(33%) RPS target by 2020.
D. By December 31, 2018, Truckee Donner shall demonstrate that it is making
reasonable progress towards ensuring that it shall meet the thirty-three percent
(33%) RPS target by 2020.
E. By December 31, 2019, Truckee Donner shall demonstrate that it is making
reasonable progress towards ensuring that it shall meet the thirty-three percent
(33%) RPS target by 2020.
5. Procurement Requirements — Definitions for Eligible Resources (§399.30 (i))
Truckee Donner's RPS Procurement Plan that will include eligible renewable energy
resources, defined pursuant to Public Utilities Code section 399.30 (i);
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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.
B. Grandfathered Resources 0 399.16(d)): Any contract or ownership agreement
originally executed prior to June 1, 2010, shall count in full towards the
procurement requirements, if all of the following conditions are met:
(1) The renewable energy resource was eligible under the rules in place as
of the date when the contract was executed.
(2) Any contract amendments or modifications occurring after June 1,
2010, do not increase the nameplate capacity or expected quantities of
annual generation, or substitute a different renewable energy resource.
(3) The duration of the contract may be extended if the original contract
specified a procurement commitment of fifteen (15) or more years.
(4) "Eligible renewable energy resource" means an electrical generating
facility that meets the definition of a "renewable electrical generation
facility" in Section 25741 of the Public Resources Code, subject to the
following: ... (C) A facility approved by the governing board of a local
publicly owned electric utility prior to June 1, 2010, for procurement to
satisfy renewable energy procurement obligations adopted pursuant to
former Section 387, shall be certified as an eligible renewable energy
resource by the Energy Commission pursuant to this article, if the facility
is a "renewable electrical generation facility" as defined in Section 25741
of the Public Resources Code. (§ 399.12(e)(1)(C).
6. Portfolio Balancing Procurement Requirements — Ouantity of Content Categories
(§ 399.30(d)(1), §399.13(a)(4)(B))
Not applicable to Truckee Donner due to (§399.30 (i)) above at 5.
7. Excess Procurement (§ 399.30(d)(1), §399.13(a)(4)(B))
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Truckee Donner shall be allowed to apply excess procurement (Excess Procurement)
from one compliance period to subsequent compliance periods as long as the following
conditions are met:
A. Truckee Donner may accumulate, beginning on January 1, 2011, Excess
Procurement from one Compliance Period to be applied in any subsequent
Compliance Period.
In calculating the quantity of Excess Procurement, Truckee Donner shall
deduct from actual procurement quantities, the total amount of
procurement associated with contracts of less than ten (10) years in
duration.
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Excess Procurement = (EPcP)(RPScP+ S3cP+ STCcP�
Where,
EPcP = Electricity vroducts retired and avvlied toward the RPS vrocurement target for the
compliance period CP
RPScP= The RPS procurement target calculated in section 3204(a) of the RPS Regulations,
for the compliance period CP
S3cP= Retired PCC 3 RECs that meet the criteria of section 3202 (a)(1) in excess of the
maximum calculated in section 3204 (c) for the compliance period CP
.STCcP= All electricity products that meet the criteria of section 3202 (a)(1) or section 3202
(a)(3), are associated with contracts less than 10 years in duration, and are retired and
applied toward the RPS procurement target for the
Waiver of Timely Compliance (§ 399.30(d)(2), § 399.15(b)(5))
A. Waiver of Timely Compliance: Enforcement of timely compliance shall be
waived if Truckee Donner demonstrates that any of the following conditions are
beyond Truckee Donner's control, and will prevent timely compliance:
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Inadequate Transmission (§ 399.15(b)(5)(A)): There is inadequate
transmission capacity to allow for sufficient electricity to be delivered
from Truckee Donner's proposed eligible renewable energy resource
projects using the current operational protocols of Truckee Donner's
Balancing Authority (NV Energy). In making its findings relative to the
existence of this condition, Truckee Donner's deliberations shall include,
but not be limited to the following:
(i) Whether Truckee Donner has undertaken, in a timely fashion,
reasonable measures under its control and consistent with its obligations
under local, state, and federal laws and regulations, to develop and
construct new transmission lines or upgrades to existing lines intended to
transmit electricity generated by eligible renewable energy resources. In
determining the reasonableness of Truckee Donner's actions, Truckee
Donner shall consider its expectations for full -cost recovery for these
transmission lines and upgrades, and
(ii) Whether Truckee Donner has taken all reasonable operational
measures to maximize cost-effective deliveries of electricity from eligible
renewable energy resources in advance of transmission availability.
2. Permitting, interconnection, or other factors that delayed procurement or
insufficient supply (399.15(b)(5)(B)). In making its findings relative to the
existence of this condition, Truckee Donner's deliberations shall include,
but not be limited to the following:
(i) Whether Truckee Donner prudently managed portfolio risks,
including relying on a sufficient number of viable projects;
(ii) Whether Truckee Donner sought to develop one of the
following: its own eligible renewable energy resources, transmission to
interconnect to eligible renewable energy resources, or energy storage
used to integrate eligible renewable energy resources.
(iii) Whether Truckee Donner procured an appropriate minimum
margin of procurement above the minimum procurement level necessary
to comply with the renewables portfolio standard to compensate for
foreseeable delays or insufficient supply;
(iv) Whether Truckee Donner has taken reasonable measures,
under its control to procure cost-effective distributed generation and
allowable unbundled renewable energy credits;
(v) Whether actions or events beyond the control of Truckee
Donner have adversely impacted timely deliveries of renewable energy
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resources including, but not limited to, acts of nature, terrorism, war, labor
difficulty, civil disturbance, or market manipulation.
Unanticipated curtailment to address needs of the balancing authority
(§ 399.15(b)(5)(C)).
B. Procedures Upon Approving Waiver: In the event of a Waiver of Timely
Compliance due to any of the factors set forth above, Truckee Donner shall
implement the following procedures:
Establish additional reporting for intervening years to demonstrate that
reasonable actions under the Truckee Donner's control are being taken
(§399.15(b)(6)).
2. Require a demonstration that all reasonable actions within Truckee
Donner's control have been taken to ensure compliance in order to grant
the waiver (§ 399.15(b)(7)).
C. Prior Deficits: In no event shall deficits from prior compliance periods be added
to future compliance periods (§ 399.15(b)(9)).
Cost Limitations for Expenditures (§ 399.30(d)(3), § 399.15(c))
AA —Cost Limitations for Expenditures: Truckee Donner, at its sole discretion, may
elect to establish cost limitations for all eligible renewable energy resources used to
comply with the renewables portfolio standard. Any such cost limitations will be
developed consistent with §399.15(c) and 399.15(d). -r,. ekee Donner- shall review *'
need fer- eest limitations as paA of the annual review pr-eeess deser-ibed in Seetion 12.
B. In adopting these rules. Truckee Donner shall relv on this procurement elan. as
well as: 1) procurement expenditures that approximate the expected cost of
building, owning and operating eligible renewable energy resources, and 2) the
potential that some planned resource additions may be delayed or canceled.
C. In addition to section §399.15(c), Truckee Donner may take into account local
and regional economic conditions and the ability of Truckee Donner customer s to
afford produced or procured energy products. These economic conditions may
include but are not limited to unemployment, wages, cost of living expenses, the
housing market, and cost burden of other utility rates on the same customers.
Truckee Donner may also consider cost disparities between customers classes
within the District, and between Truckee Donner customers and other POU and
IOU customers in the region.
D. Truckee Donner shall review the need for cost limitations as part of the annual
review process described in Section 13.
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10. Historic Carryover
A. Truckee Donner. at its sole discretion. may elect to adopt rules that allow for
procurement generated before January 1, 2011 that meets the criteria of Section
3202 (a)(2), that is in excess of the sum of the 2004-2010 annual procurement
targets defined in Section 3206(a)(5)(D) and that was not applied to the RPS of
another state or to a voluntary claim, to be applied to the POU's RPS procurement
target for the compliance period ending December 31, 2013, or for any
subsequent compliance period.
B. Both the historic carryover and the procurement applied to the POU's annual
procurement target must be from eligible renewable resources that were RPS-
eligible under the rules in place at the time of execution of ownership agreement.
a. Historic carryover must be procured pursuant to a contract or ownership
agreement executed before June 1, 2010.
C. Historic carryover will be calculated based on the following:
a. A baseline of an amount equal to 2001 procurement divided by 2001 retail
sales, multiplied by 2003 total retail sales, plus one percent of 2001 retail
sales.
b. Annual procurement targets for 2004-2010 that are equal to the lesser of 20
percent of the previous year's retail sales or one percent of the previous year's
retail sales greater than the annual procurement target for the previous year.
D. All applicable historic procurement claims for January 1, 2004 — December 31,
2010, baseline calculations, annual procurement target calculations, and any other
pertinent data must be submitted to the California Energy Commission by
December 30, 2013.
101. Exclusive Control (§399.30(#ik�);—In all matters regarding commliance with the RPS Formatted: Highlight
Procurement Plan, Truckee Donner shall retain exclusive control and discretion over the
following:
A. The mix of eligible renewable energy resources procured by Truckee Donner and
those additional generation resources procured by Truckee Donner for purposes of
ensuring resource adequacy and reliability.
B. The reasonable costs incurred by Truckee Donner for eligible renewable energy
resources owned by it.
1472. Reporting (§ 399.30(f), and 9605 of the CEC Re ulat j2R2 , Formatted: Highlight
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A. Deliberations on Procurement Plan (§399.30(f)):
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Public Notice: Annually, Truckee Donner shall post notice of meetings if
the Board will deliberate in public regarding this RPS Procurement Plan.
2. Notice to the California Energy Commission (CEC): Contemporaneous
with the posting of a notice for such a meeting, Truckee Donner shall
notify the CEC of the date, time and location of the meeting in order to
enable the CEC to post the information on its Internet website.
Documents and Materials Related to Procurement Status and Plans:
When Truckee Donner provides information to the Board related to its
renewable energy resources procurement status and future plans, for the
Board's consideration at a noticed public meeting, Truckee Donner shall
make that information available to the public and shall provide the CEC
with an electronic copy of the documents for posting on the CEC's
Internet website.
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development, e e
and
expeeted,laetual .,its
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B. Compliance Reporting (per Section 3207 of the CEC RPS Regulations
1. Annual Reports — by 1 for each see Section 3206(c))
Truckee Donner shall submit an annual report to the CEC that includes the information in
paragraphs (1) - (4) below for the prior calendar year. The report submitted in 2013 shall include
information required by paragraphs (1)-(4) below for both the 2011 and 2012 calendar
The format for the annual report shall be specified by the CEC, but the information contained in
the annual report may be combined with other existing reports that contain the same
information and are also supplied to the CEC. If the annual report refers to information
provided to the CEC through existing reports, the annual report shall reference the information
by identifying the name, submittal date, and page number of the existing report. Included in
the report will be the following:
(1) Identifying information, including_
(A) POU name, contact name, mailing address, phone number, and e-mail
address.
(B) Year Truckee Donner's electric utility was established.
(C) Number of end -use retail customer accounts in California.
(2) RPS annual progress information for the prior calendar year, including:
(A) Amount of total retail sales to end -use customers, in MWh, and projected
retail sales for the current compliance period.
(B) Amount of procured electricity products retired, in MWh.
(C) WREGIS compliance report for procurement claims in the prior calendar
year. For any procurement claims not tracked through WREGIS as permitted by the RPS
Guidelines, Truckee Donner shall report procurement claims using the interim tracking
system established by the Commission prior to the implementation of WREGIS.
(D) An initial, nonbinding classification of retired electricity products qualifying
for each portfolio content category or qualifying to count in full in accordance with
section 3202 (a)(2).
(E) A description of each of the eligible renewable energy resources with which
Truckee Donner has executed contracts or ownership agreements during the prior year,
including but not limited to the contracted amount of MWh, the contracted amount of
MWh as a percentage of retail sales, resource fuel type, the execution date of the
procurement contract or ownership agreement, the duration of the procurement contract
or ownership agreement, a summary of the procurement contract or ownership
agreement, the operational status of the resource, the date the resource came on-line, the
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date the resource came on-line using a renewable fuel or technology, if different, the
date on which procurement of electricity12roducts begins, if different, RPS certification
status, the county, state, and country in which the resource is located, and a summary of
the resource names and identification numbers.
(F) Documentation demonstrating the portfolio content category classification
claimed for procured electricity products. This documentation may include
interconnection agreements, NERC e-Tag data, scheduling agreements, firming and
shaping agreements, and electricity product contract information.
(G) An explanation of any public goods funds collected for eligible renewable
energy resource development, including a description of programs, expenditures, and
expected or actual results.
(H) A description of any identified issues that occurred that have the potential to
delay timely compliance with the RPS procurement requirements defined in section
3204, and planned actions to minimize the delay of timely compliance. Such issues may
include, but are not limited to, inadequate transmission to allow for procurement to be
delivered from eligible renewable energy resources, permitting, interconnection, or
other circumstances that have delayed the procurement from eligible renewable energy
resources, unanticipated curtailment of a contracted or owned eligible renewable energy
resource, and higher -than -expected costs for the procurement or development of eligible
renewable energy resources.
(1) An attestation, signed by an authorized agent, affirming that the information
provided in the report is true and correct.
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RPS procurement requirements. The information reported shall include, but not be
limited to, a discussion of the following actions taken by Truckee Donner during the
prior calendar year:
(A) Solicitations released to solicit bid for contracts to procure electricity products
from eligible renewable energy resources to satisfy Truckee Donner's RPS
procurement requirements.
(B) Solicitations released to solicit bid for ownership agreements for eligible
renewable energy resources to satisfy Truckee Donner's RPS procurement
requirements.
C) Actions taken to develop eligible renewable enersv resources to satisfv Truckee
Donner's RPS procurement requirements, including initiating environmental
studies, completing environmental studies, acquiring interests in land for facility
siting or transmission, filing applications for facility or transmission siting
permits, and receiving approval for facility or transmission siting permits.
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(D) Interconnection requests filed for eligible renewable energy resources to satisfy
Truckee Donner's RPS procurement requirements.
(E) Interconnection agreements negotiated and executed for eligible renewable
energy resources to satisfy Truckee Donner's RPS procurement requirements.
(F) Transmission -related agreements negotiated and executed to transmit electricity
products procured from eligible renewable energy resources to satisfy Truckee
Donner's RPS procurement requirements.
(G) Other planning activities to procure electricity products from eligible renewable
energy resources.
(4) Truckee Donner shall include a description of all actions planned in the current
calendar year to demonstrate progress towards achieving its RPS procurement
requirements.
2. Compliance Period Reports — by July 1 of 2014, 2017, 2021, and annually thereafter.
(see Section 3207(d) of the CEC RPS Regulations)
By fuly 1, 2014; July 1, 2017; luly 1, 2021; and by 1 of each year thereafter, Truckee Donner
shall submit to the CEC a compliance report that addresses the reporting requirements of the
previous section and the following information for the preceding compliance period
(1) Classification per RPS-certified facility of the amount of procurement qualifying for
each portfolio content category and procurement that shall count in full.
(2) Truckee Donner's RPS procurement target for the compliance period, in MWh.
(3) The amount of excess procurement, in MWh, from previous compliance periods, if
any, and historic carryover, if any, that Truckee Donner is applying to the compliance period.
(4) The amount of procurement retired, in MWh, that Truckee Donner wishes to claim
toward the RPS procurement target for calculating the portfolio balance requirements.
(5) The amount of excess procurement, in MWh, for the compliance period, if any, that
may be applied toward future compliance periods.
(6) If the compliance report indicates that Truckee Donner's RPS procurement
requirements were not met, Truckee Donner shall provide documentation to justify
application of any optional compliance measures adopted in accordance with this plan. The
documentation shall include all reports, analyses, proposed findings, and any other information
upon which Truckee Donner relied in applying the measure. Truckee Donner shall also submit
an updated enforcement program and/or procurement plan that includes a schedule identifying
potential sources of electricity products currently available or anticipated to be available in the
future for meeting the shortfall.
(A) If Truckee Donner applies adopted cost limitation measures, it shall report that cost
limitation to the CEC in dollars spent during the compliance period. Truckee Donner shall also
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provide the CEC with an estimate of the total cost to procure sufficient electricity products to
meet its RPS procurement requirements for the preceding compliance period. A report on
actions taken in response to RPS procurement expenditures meeting or exceeding the cost
limitation shall also be provided.
123. Program Review
Truckee Donner's RPS Procurement Plan shall be reviewed by the Board of Directors in
accordance with Truckee Donner's "Renewable Portfolio Standard Enforcement Program."
134. Plan Modifications/Amendments
This RPS Procurement Plan may be modified or amended by an affirmative vote of the Board of
Directors during a public meeting. Any Board action to modify or amend the plan must be
publicly noticed in accordance with Section 11.
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