Renewable Power Resources

On behalf of Public Power, I am asking that you join us in our opposition to SB 14 and AB 64 unless they are amended. Public Power supports the target achieving 33% renewable resources by 2020 and recognizes that renewable resources will play a key role in meeting our greenhouse gas reduction requirements. Under AB 32, the California Global Warming Act of 2006, Public Power has already adopted aggressive renewable portfolios standard (RPS) to help meet those requirements.

The ability to access renewable energy supplies over the next 10 years will be severely affected by the need to build infrastructure to deliver clean energy supplies to meet customer demand. Procurement strategies for renewable resources should be guided by the availability of transmission capacity, maintenance of grid reliability and lowest cost to consumers. The ambitious 33% RPS goal necessitates procurement of cost-effective resources wherever they can be found and be deliverable to California.

The provisions of SB 14 and AB 64 in effect, prohibit all utilities from meeting the objectives by disqualifying many of the out-of-state renewable resources that are already in existence and already under contract. Specifically, the definition of “delivery” in SB 14 and “simultaneous consumption” in AB 64 could leave utilities to meet 33% goal while limited to California-only renewable resources. The 33% goal will almost certainly place upward pressure on rates. To add these additional, anti-competitive burdens on wholesale markets will only increase this pressure and make California a more expensive place to do business. In addition, such policies could result in increased prices for renewables, slower development of new renewable resources, and reduced reliability of the electric grid. Therefore, the ability to meet renewable goals with cost-effective options across the West should be an essential element of this legislation.

The interests of the state’s electric consumers must be safeguarded in the effort to achieve a goal of 33% RPS. The reliability of the electric grid must be maintained as we incorporate more renewables into the system. There must be mechanisms for flexible compliance so that utilities can achieve the state goal of 33% in the most economic and efficient manner. Furthermore, restricting a 33% RPS to a California-only option needlessly drives up the costs to consumers by stranding investment in existing and much needed transmission and delays the ability of utilities to not only achieve the RPS goal, but also makes it more difficult to achieve the state’s AB 32 goals for greenhouse gas emission reduction.

For these reasons, I respectfully requests that you join in our opposition and voice these concerns. Please write your legislator and ask them to oppose both of these bills unless amended. As currently written SB 14 and AB 64 could prevent your utility from counting out-of-state renewable resources toward the state’s proposed 33% RPS goal