BILL ANALYSIS                                                                                                                                                                                                                   1
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             SENATE ENERGY, UTILITIES AND COMMUNICATIONS COMMITTEE
                            DEBRA BOWEN, CHAIRWOMAN
          

          SB 39X - Speier                                         
          Hearing Date:  February 22, 2001       S
          As Introduced:  February 8, 2001        FISCAL           B
                                                                       
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                                   DESCRIPTION
           
          This bill seeks to clarify and enhance the state's  
          regulatory authority over in-state electric generation  
          facilities.  Specifically, this bill:

          1.Repeals a provision of AB 1890 that states ownership of a  
            wholesale generator does not necessarily make the owner a  
            "public utility."  The effect of this is to subject these  
            generators to the "jurisdiction, control, and regulation"  
            of the California Public Utilities Commission (CPUC), to  
            the extent permitted by federal law.

          2.Requires the CPUC to ensure that generators are operated  
            in a manner that ensures their availability to maintain  
            reliability, and authorizes the CPUC to prohibit economic  
            and physical withholding of power to accomplish such  
            operation.

          3.Authorizes the CPUC to prescribe inspection, maintenance  
            and operating procedures for generators to ensure public  
            health and safety and reliability.

                                    BACKGROUND
           
          The federal Public Utility Holding Company Act of 1935  
          (PUHCA) authorized the Securities and Exchange Commission  










               (SEC) to monitor public utility holding companies to  
               protect consumers and investors.  At the time of PUHCA's  
               passage, it was found that the activities of holding  
               companies engaged in interstate commerce affected the  
               public interest, but were not effectively regulated by  
               state utility commissions.

               The sentiment of the time is best expressed in PUHCA's  
               policy declaration:

                    When abuses? become persistent and wide-spread  
                    the holding company becomes an agency which,  
                    unless regulated, is injurious to investors,  
                    consumers, and the general public; and it is  
                    declared to be the policy of this chapter? to  
                    meet the problems and eliminate the evils as  
                    enumerated in this section, connected with  
                    public-utility holding companies which are  
                    engaged in interstate commerce or in activities  
                    which directly affect or burden interstate  
                    commerce; and for the purpose of effectuating  
                    such policy to compel the simplification of  
                    public-utility holding-company systems and the  
                    elimination therefrom of properties detrimental  
                    to the proper functioning of such systems, and to  
                    provide as soon as practicable for the  
                    elimination of public-utility holding companies  
                    except as otherwise expressly provided in this  
                    chapter.

               By 1992, sentiments in Congress had changed and PUHCA was  
               amended to, among other things, exempt purely wholesale  
               generators owned by public utility holding companies from  
               SEC regulation.

               These exempt wholesale generators (EWGs) are the  
               enterprises that have acquired most of the natural  
               gas-fired generation facilities divested by California's  
               investor-owned utilities (IOUs).  They are affiliates of  
               public utilities from other states, such Duke, Reliant, and  
               Southern (Mirant), held in common by holding companies.   
               California IOUs have also established holding companies  
               which own EWGs, both within California and in other states.

               In AB 1890 (Brulte), Chapter 854, Statutes of 1996, EWG  









          owners were specifically exempted from the definition of a  
          "public utility" to avoid any suggestion that they would be  
          subject to CPUC "jurisdiction, control, and regulation" of  
          public utilities required by Section 216 of the Public  
          Utilities Code.

          The change made by AB 1890 did not itself surrender  
          regulation of EWGs.  It was consistent with the changes to  
          federal law and regulatory policy which created a merchant  
          class of generators that could be owned by the holding  
          company of a regulated utility, but would not itself be  
          subject to either SEC or state utility commission  
          regulation.

                                     COMMENTS
           
           1.Will the horse come back to the barn?   The bill is  
            intended to recapture regulatory authority surrendered in  
            AB 1890 and to authorize the CPUC to use that authority  
            to regulate matters which are recognized as state  
            jurisdictional - reliability, health and safety (not  
            wholesale rates).

            It is not clear that undoing the provision of AB 1890,  
            without concomitant changes to federal law and regulatory  
            policy, will compel EWGs, which have profited from their  
            freedom from state regulation, to submit to effective  
            CPUC regulation.  The extent to which the CPUC can  
            enforce the provisions of this bill may depend on whether  
            federal authorities, or the courts, agree that these  
            matters are appropriate for state regulation.

           2.Withholding companies?   One of the allegations of the  
            current energy market crisis is that generators have  
            engaged in economic or physical withholding of power to  
            increase prices.  Economic withholding is when a  
            generator refuses to sell power at a price acceptable to  
            the buyer in order to increase the price for a later  
            sale.  Physical withholding is when a generator  
            deliberately stops generating power in order to increase  
            the price for a later sale, or for another generator's  
            sale.

            This bill authorizes the CPUC to prevent both economic  
            and physical withholding in order to prevent "the  









                 exercise of market power."  Neither economic nor physical  
                 withholding has a well-established definition or is  
                 defined in the bill.  The CPUC will be left the difficult  
                 task of drawing the line between withholding as hard  
                 bargaining and withholding as inappropriate market  
                 manipulation.

                 Preventing "the exercise of market power" is more likely  
                 a federal, rather than state, jurisdictional issue.  The  
                 author and the committee may wish to consider  instead  
                 authorizing the CPUC to prohibit withholding to "ensure  
                 reliability."

                3.Inspection, maintenance and operation.   Another  
                 circumstance of the current energy market crisis is that  
                 California has been plagued by unprecedented generator  
                 outages which have increased prices, undermined  
                 reliability, and have the potential to adversely impact  
                 public health and safety.

                 Generator outages for planned maintenance are currently  
                 scheduled by the Independent System Operator (ISO).  The  
                 ISO does not have the enforcement power of the CPUC, but  
                 as control area operator, it has a unique ability to  
                 monitor unscheduled outages.  

                 This bill authorizes the CPUC to prescribe inspection,  
                 maintenance and operating practices and procedures for  
                 generators.   The author and the committee may wish to  
                 consider  ensure that the CPUC takes advantage of the  
                 ISO's expertise, rather than attempt to duplicate it, by  
                 requiring the CPUC to consult with the ISO in carrying  
                 out this duty.

                4.Executive Order.   On February 8, Governor Davis issued  
                 Executive Order D-23-01 relating to generator outages.   
                 The Order required the ISO to obtain planned outage  
                 schedules from generators, prepare a coordinated outage  
                 plan, identify maintenance criteria and establish  
                 performance benchmarks for generators.  The ISO is  
                 currently in the process of implementing the Order.

                                         POSITIONS
                
                Sponsor:  










          Author

           Support:  
          None on file

           Oppose:  
          None on file

          Lawrence Lingbloom 
          SB 39X Analysis
          Hearing Date:  February 22, 2001