HomeMy WebLinkAbout8-2,Procurement Plan-Draft Update-finalAttachment 2, Final
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: Minute Order XX, 2013
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 Regulation; and (3) RPS reporting
provisions. Where appropriate, this RPS Procurement Plan includes section citations to Public
Utilities Code (PUC) sections 399.11, et seq, as last revised in 2012.
1. 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.
B. Compliance Period 2: January 1, 2014, to December 31, 2016, 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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C. Compliance Period 3: January 1, 2017, to December 31, 2020, inclusive.
D. Annual Compliance Periods: Annually after 2020.
3. Procurement Targets of Renewable Energy 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:
Where:
EP 2011 + EP 2012 + EP 2013 > .20
RS 2011 + RS 2012 + RS 2013
RS,, = 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 by
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)."
B. 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 2014 + EP2015 + EP2016 > 0.20(RS2014) + 0.20 (RS2015) + 0.25 (RS2016)
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:
(EP2017 + EP2018 + EP2019 + EP2020)
> 0.27 (RS2017) + (0.29 (RS2018) + 0.31 (RS2019) + 0.33 (RS2020)
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.
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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);
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.
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A. Eligible renewable energy resources (consistent with . 39�9.30(i)): includes a facility
that is located outside California that is connected to the WECC transmission system.
B. Grandfathered Resources (§ 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 — Quantity 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))
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.
B. 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 products retired and applied toward the RPSprocurement 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
8. 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:
1. 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:
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(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 resources
including, but not limited to, acts of nature, terrorism, war, labor difficulty,
civil disturbance, or market manipulation.
3. 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:
1. 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)).
9. Cost Limitations for Expenditures (§ 399.30(d)(3), § 399.15(c))
A. A 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
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with the renewables portfolio standard. Any such cost limitations will be developed
consistent with §399.15(c) and 399.15(d).
B. In adopting these rules, Truckee Donner shall rely on this procurement plan, 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.
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.
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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.
11. Exclusive Control (§399.30(k)): In all matters regarding compliance with the RPS
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.
12. Reporting (§ 399.30(f), and 9605 of the CEC Regulations
A. Deliberations on Procurement Plan (§399.30(f)):
1. 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.
3. 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.
B. Compliance Reporting (per Section 3207 of the CEC RPS Regulations):
1. Annual Reports — by July 1 for each year (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 years. 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
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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 date the resource came on-line using a
renewable fuel or technology, if different, the date on which procurement
of electricity products 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.
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(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.
(I) An attestation, signed by an authorized agent, affirming that the
information provided in the report is true and correct.
(3) Actions taken by Truckee Donner demonstrating reasonable progress toward
meeting its 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 energy resources to satisfy
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.
(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.
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(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 July 1, 2014; July 1, 2017; July 1, 2021; and by July 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 the 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 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
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on actions taken in response to RPS procurement expenditures meeting or
exceeding the cost limitation shall also be provided.
13. 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."
14. 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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