Joint Procurement Implementation Advice Letter Workshop ...The webinar is scheduled for 1.5 hours,...

Joint Procurement Implementation Advice Letter Workshop Webinar

April 20, 2015

Presented by:

Pacific Gas and Electric Company

San Diego Gas and Electric Company

Southern California Edison Company

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Joint Procurement Implementation Advice Letter

Objective: To review and receive input on proposed contents of the Investor Owned Utilities

(IOUs) Green Tariff Shared Renewables (GTSR) Program Joint Procurement Implementation Advice Letter (JPIAL), which covers the following topics:

• Renewable Energy Credit (REC) and Renewables Portfolio Standard (RPS) resource tracking and reporting

• Dedicated procurement for the GTSR (including Enhanced Community (ECR)) program

Not in Scope: Topics related to marketing (including MIAL), customer issues (including CSIAL), rate design, Renewables Portfolio Standard (RPS) backstop and interim pool, debating the final Commission decision implementing GTSR (D.15-01-051), Phase IV, and advanced procurement.

Statement from the �alifornia Public Utilities �ommission’s Energy Division

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Webinar Guidelines:

1. The webinar is scheduled for 1.5 hours, ending at 11:30 a.m.

2. The IOUs will give the presentation and a Question and Answer (Q&A) session will be held at the end of the presentation.

3. Participants will be on mute until the Q&A. During the Q&A, participants may ask a question by phone and through WebEx:

• By Phone: Press *1

• Through WebEx: Use chat function

4. If at 11:30 a.m., not all participants questions have been answered, participants may send their questions to one of the IOU email addresses, below. Please note, messages must be received by April 22nd for consideration in the JPIAL.

PG&E: [email protected] SCE: [email protected] SDG&E: [email protected]

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mailto:[email protected]




Agenda: • Background

GTSR Program Current Status: Previous and Parallel Advice Letters, Phase IV

• Contents of JPIAL RPS Resource Separation and REC Tracking

o Annual REC Reporting Template Ongoing Procurement: Green Tariff

o Green Tariff Procurement: Incremental and Additional Ongoing Procurement: Enhanced Community Renewables

o ECR Procurement: ECR Tariff and ReMAT PPA with Rider Environmental Justice Green-e Certification

• Brief Intermission

• Question and Answer Session 4

BACKGROUND

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Background: Senate Bill (SB) 43 (Stats. 2013, ch. 413 (Wolk)) establishes the GTSR Program, a 600 megawatt (MW) statewide program that allows the customers of investor-owned utilities – including local governments, businesses, schools, homeowners, municipal customers, and renters – to purchase up to 100 percent of their electricity from a renewable resources.

• The IOUs will be procuring new solar resources located in each IOU’s respective service territory, sized .5-20MW, to support demand for their GTSR programs, using Commission approved procurement mechanisms.

• The IOUs will be using a pool of existing RPS resources to support the program until new GTSR dedicated projects come online (Green Tariff only).

• The ECR aspect of the program allows customers to contract directly with a third-party renewable developer to subscribe to a specific local renewable facility.

• Both GTSR and ECR procurement include consideration for projects located in “the most impacted and disadvantaged communities”.

Date Event

2012/2013 SDG&E and PG&E filed applications for the GTSR Program

September SB 43 signed into law 2013

January SCE filed application 2014 for the GTSR Program

February Phase I hearings on 2014 ECR component of the

GTSR Program

December Proposed Decision 2014 issued by the CPUC

February Final Decision issued 2015 by the CPUC

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Current Status: Date Event Description Status

February 19, 2015 Request to extend the timeframe for the IOU’s 6th Renewable Auction Mechanism (RAM 6)

IOUs are permitted to submit a letter to the �ommission’s Executive Director seeking an extension of the RAM 6 June 30, 2015 deadline if more time is needed to procure GTSR projects through RAM 6

Filed. Supplemental filings filed by

SCE and PG&E.

February 23, 2015 Advance Procurement Plan Advice Letter

Confirms IOU plan to begin advance procurement in ReMAT and RAM 6 (if applicable); List EJ areas and include initial GTSR procurement target for RAM 6 (if any) and ReMAT

Filed.

March 4, 2015 Response to RAM 6 extension request

Commission response to IOU request to delay RAM 6 to incorporate advance procurement for the GTSR program

Issued, request approved.

March 19, 2015 RAM 6 PPA and/or RFO Instructions

IOUs filed its RAM 6 PPAs and Protocols which includes necessary modifications for GTSR procurement in RAM 6.

Filed.

April 20, 2015 JPIAL Workshop To provide an informal platform for input and discussion on the JPIAL.

Today.

May 13, 2015 Joint Procurement Implementation Advice Letter

Details procurement process, including compliance reports, post-2015 procurement and separation between RPS and GTSR resources.

On schedule.

May 13, 2015 Customer Side and Marketing Implementation Advice Letters

IOUs each file advice letters related to customer side and marketing implementation of the GTSR program

On schedule.

Later of August 21, 2015 or 60 days following approval of the IOUs RAM 6 PPA and RFO Instructions.

First GTSR solicitation (with RAM)

Per Commission direction for advance procurement for the GTSR program and approval of the request to extend the RAM 6 solicitation, the IOUs commence procurement for the GTSR program.

On schedule.

August 7, 2015 Phase IV, Track A The schedule for Track A of Phase IV recently issued. On schedule.

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GTSR RESOURCE TRACKING AND RPS SEPARATION

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RPS Separation and REC Tracking: GTSR Interim Pool (for Green Tariff only)

• The IOUs will identify a pool of existing RPS resources in accordance with D.15-01-051 to serve customers until enough GTSR dedicated resources are online to support customer enrollments.

Methodology for REC tracking and maintaining separation between interim GTSR pool and RPS resources

Year 1 Interim Pool

Additional Volume (Y MWh)

Year 1 Interim Pool

GTSR Volume

(X MWh)

Total Interim Pool Volume

Separate GTSR Volume from Total Interim Pool Volume

RPS Compliance

Process

Add X RECs to GTSR WREGIS Retirement Folder

on Behalf of Customers

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GTSR Customers

Year 1GTSR

Demand (X MWh)

Year 1 Interim Pool Total Generation

(X MWh + Y MWh)

Interim Pool

Year 1GTSR

Volume (X MWh)

Total GTSR Volume Needed

Charge GTSR Customers for X MWh using Weighted Average Cost of Interim Pool

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Use Y RECs for RPS

Compliance

REC • Renewable energy credit • 1 REC = 1 MWh of renewable

energy WREGIS • Online tracking system for

RECs • REC data recorded in WREGIS is used to verify an IOU’s procurement of RECs

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RPS Separation and REC Tracking (cont.):

Tracking Impact on RPS Residual Net Short and RECs

• RPS tracking and forecasting models will be adjusted to reflect the projected growth of the GTSR program and the actual or projected transfer of generation from the interim GTSR pool to the RPS program at start-up and any projected transfers from the GTSR program to the RPS Program in the event of over-procurement.

• Key RPS reports will be updated to reflect the results of these forecast models.

• These RPS reports will include the annual RPS compliance report and latest quarterly PRG residual net short (RNS) update. A line item will be added to the RNS template to show volumes subtracted for the GTSR program.

• Each IOU’s annual RPS plan will also incorporate the impacts of the GTSR program in its RPS compliance position projections.

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Annual Reporting Template Subject to Change

This template (based on the RPS Compliance Report) is an annual report that tracks the amount of generation transferred between the two programs (both RPS to GTSR at start-up and GTSR to RPS in the event of over procurement). This report includes:

• Title Page • Instructions Tab • Transfer Summary Tab • GTSR Transfer Detail Tab • Officer Verification

Subject to Change

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ONGOING PROCUREMENT: GREEN TARIFF

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Green Tariff Procurement: Incremental and Additional One of the key principles of the GTSR Program is “non-participating ratepayer indifference.” To help maintain “non-participating ratepayer indifference” each IOU plans to procure GTSR resources for the Green Tariff portion of the program to meet incremental customer enrollment and in addition to procurement that would have otherwise taken place (ECR procurement discussed on slide 12):

• The IOUs will use a RAM-like process (RAM tool) for ongoing GTSR procurement via the RPS solicitation. RAM has been a successful procurement tool for the IOUs to meet their RPS targets and is currently in its 6th an nual cycle.

• Standardized Methodology to Determine Additionality

o Each IOU will set procurement targets in accordance with its incremental increase in customer demand.

PG&E: PG&E will hold a solicitation for new GTSR projects the earlier of 30MW of incremental customer enrollments or a calendar year, subject to de minimis incremental customer enrollments.

SDG&E: Once 5 MW are subscribed, SDG&E will procure an additional 5 MW.

SCE: SCE will update RPS Plan annually with procurement needs for Green Tariff based on actual demand and existing dedicated procurement.

• Each IOU will establish procurement guidelines, including preferences for project locations and size (e.g. Environmental Justice) as part of each utility’s Protocol that governs the solicitation.

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ONGOING PROCUREMENT: ENHANCED COMMUNITY RENEWABLES

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Enhanced Community Renewables: The Enhanced Community Renewable (ECR) aspect of the GTSR program allows customers to contract directly with a third-party renewable developer to subscribe to the output of a specific local renewable facility. In effect, ECR is a three party structure that requires different agreements among the different parties.

Developer

IOUCustomer

ECR Tariff

Energy (based on usage)

Standard Bill Charges (usage)

+/ ECR Program Charges

Solar Gen Credit (production)

ECR Customer Bill

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Enhanced Community Renewables: Project Requirements

• Between 0.5 MW and 3 MW

• At least three subscribers

• Subscribers all within a county or 10 miles of project site (“�ommunity of Interest”).

• Enrollment commitment of 30% of ECR Project capacity or expressed interest in 51% of ECR Project capacity

• Maximum subscription is 2 MW.

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ECR Procurement via ReMAT: New ECR Tariff The IOUs will be using ReMAT to procure ECR Projects. In order to do so, the IOUs are proposing the

following:

ECR Tariff

• The IOUs have developed a separate ‘Enhanced �ommunity Renewables Project Development Tariff’ based as closely as possible on the existing ReMAT Tariff (separate ECR Tariff created in order to maintain integrity of IOUs existing ReMAT programs).

• Under the Tariff, there will be a queue for ECR projects ECR projects.

• PG&E and SCE will each offer 5MW and SDG&E will offer 3MW to the ECR queue each Program Period (subject to MW caps and conclusion of the GTSR program).

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ECR Rider

• ReMAT form PPA + ECR Rider = ECR PPA (ReMAT form PPA remains unmodified) o The ECR Rider is used in conjunction with, and as an amendment to, the ReMAT PPA and

outlines additional obligations unique to the ECR structure, and in some cases, replaces language in the ReMAT PPA (Billing). 17

ECR PPAs will use the contract price of each IOU’s current ReMAT Peaking As-Available Bucket as it applies to unsubscribed energy under the ECR PPA. The ECR contract price applies under specific conditions per D.15-01-051 related to customer subscription levels.


ECR via ReMAT: Key Tariff and Rider Provisions Term Description

Marketing IOU must review marketing materials before developer can solicit subscribers.

Community Interest & Location Requirements

Developer to provide attestation of minimum subscriber requirements at application prior to executing PPA. Developer to submit information about actual subscribers at PPA and again at COD (e.g. customer name, address, account number, subscription amount) for IOU verification.

Green-e Product must be Green-e Energy certified. Tracking System Attestation required every three years. CR Rider includes representations, warranties and covenants regarding Green-e eligibility.

Environmental Justice (EJ) IOU reserves the right to select projects meeting EJ requirements out of queue order.

Contract Price Takes Re-MAT Peaking As-Available Price and does not impact ReMAT price. Each IOU will propose a methodology to calculate price once “Peaking !s-!vailable” �ucket is fully subscribed.

Securities Law Legal Opinion AmLaw 100 Securities opinion required at time of PPA with bring-down at COD.

Settlements Settlements will likely be expanded from 30 days after generation to 90 days to account for customer subscription verification.

Developer Payment Developer assigns right to payment under PPA from IOU to customer. Developer will receive DLAP + REC price for unsubscribed capacity when below CPUC-requires minimum and PPA contract price when over minimum (with a five percent margin).

Required Customer-Developer Agreement (CDA) Provisions

IOUs are not parties to or beneficiaries of the CDA. D.15-01-051 requires ECR Rider to include “terms regarding customer protection and developer behavior.”

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ENVIRONMENTAL JUSTICE

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Environmental Justice Pursuant to SB 43, 100 MW of the 600 MW program cap for GTSR is dedicated to

Environmental Justice (EJ) Projects, further defined in D.15-01-051 as the 20% most impacted communities based on the CalEnviroScreen Version 2.0 screening tool.

IOUs each submitted EJ census tracts as part of Implementation Advice Letters (filed Feb. 23, 2015).

Projects sized .5-1 MW

IOU Proposals for Prioritizing EJ Projects:

ReMAT ECR Tool: IOUs reserve the right to select EJ projects out of order in the queue and may prioritize EJ projects over others to the extent that the IOU has not met its EJ target.

RAM Tool in RPS: IOUs will individually propose their own EJ prioritization methodologies for the RAM Tool in RPS. Each IOU proposed to use EJ as a factor in selecting projects during RAM 6 solicitation (Advice Letter submitted on March 19, 2015).

Further discussions on EJ Prioritization will be part of Phase IV. 20


GREEN-E CERTIFICATION

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GSTR: GREEN TARIFF & ENHANCED COMMUNITY RENEWABLES

April 20, 2015

Robin Quarrier Chief Counsel Center for Resource Solutions

About Center for Resource Solutions A nonprofit creating policy and market solutions to advance sustainable energy since 1997.

SB 43/green power program at the CPUC

• Vote on 29th of Jan 2015 • Requires PG&E, SC Edison and SDG&E

to offer Green-e Energy certified renewable energy option to customers

Leading Utility Programs 9 of the 10 largest green pricing programs by participation

are Green-e Energy certified:

Portland General Electric PacifiCorp Xcel Energy Sacramento Muni. Utility Dist. Puget Sound Energy CT Light & Power/United Illuminating DTE Energy Dominion Virginia Power Iberdrola: NYSE&G, Rochester G&E We Energies

Source: US DOE, http://apps3.eere.energy.gov/greenpower/resources/tables/topten.shtml

http://apps3.eere.energy.gov/greenpower/resources/tables/topten.shtml

The Value of Green-e Energy Stakeholder-driven standards and Independent Governance Board

Green-e Energy National Standard Supply (what) Requirements for Eligible Resource Types

Marketing Green-e Energy Code of Conduct Marketing Disclosure Requirements for Sellers (how)

Green Tariff Developer Requirements

Generator must sign Green-e Energy Tracking Attestation for Electricity and RECs http://green-e.org/verif_docs.html

- RECs have not been claimed by another party

http://green-e.org/verif_docs.html

ECR Developer Requirements Posted on Green-e Website & Included in PPA Rider

Before PPA is signed Submit all marketing material to the IOU Provide required disclosures to potential customers including: customer price per kWh or kW Comply with minimum purchase size

ASAP/operational & registered in WREGIS Developer must sign Green-e tracking attestations Developer must procure host attestations

ECR Developer Disclosures Ongoing requirements

• Provide customers with a Welcome Packet • Maintain consumer facing website & customer service

number • Maintain attestations and submit to Green-e and IOU as

required • Comply with marketing and disclosure requests and

requirements of Green-e Energy and IOU

http://green-e.org/getcert_re_stan.shtml#coccdr

http://green-e.org/getcert_re_stan.shtml#coccdr

CONTACT

Robin Quarrier Chief Counsel Center for Resource Solutions 415-568-4285 [email protected]



Conclusions and Next Steps:

Conclusions • The IOUs are still finalizing the JPIAL and some aspects may be subject to

change. • We look forward to your feedback and input to make the JPIAL more

efficient and effective.

Next Steps • Brief intermission • Question and Answer

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QUESTION AND ANSWER

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END

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Joint Procurement Implementation Advice Letter Workshop ...The webinar is scheduled for 1.5 hours,...

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