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

          SB 67 -  Bowen                Hearing Date:  April 8, 2003        
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          As Introduced:  January 17, 2003        FISCAL           B
                                                                        
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                                      DESCRIPTION
           
           Existing law  (Public Utilities Code Section 701.3) requires the  
          California Public Utilities Commission (CPUC) to reserve a  
          portion of future electrical generating capacity for renewable  
          resources.

           Existing law  (Public Utilities Code Section 454.5) requires  
          investor-owned utilities (IOUs) to buy renewable resources with  
          the goal of increasing their existing level of renewable  
          resources by one percent per year until a 20 percent renewable  
          resources portfolio is achieved.

           Existing law  (SB 1078 (Sher), Chapter 516, Statutes of 2002),  
          the "Renewable Portfolio Standard" or RPS, requires IOUs to meet  
          essentially the same renewable procurement goals as Section  
          454.5, but sets a deadline of 2017 for achieving a 20 percent  
          renewable portfolio and establishes a detailed process and  
          standards for renewable procurement.  

          Under the RPS, the CPUC is prohibited from requiring an IOU to  
          buy renewable resources to fulfill the RPS until the IOU has  
          attained an investment grade credit rating as determined by at  
          least two major rating agencies.

           This bill  establishes an alternative credit test which permits  
          the CPUC to require RPS procurement when an IOU is able to buy  
          renewable resources on reasonable terms, those resources can be  
          financed if necessary, and the procurement will not impair the  
          restoration of the IOU's creditworthiness.

                                      BACKGROUND











           
          AB 57 (Wright), Chapter 835, Statutes of 2002, established a  
          process under which an IOU may be assured its electricity  
          procurement expenses will be recoverable in customer rates, if  
          the procurement is conducted consistent with a CPUC-approved  
          procurement plan.  AB 57 included a requirement that IOUs buy  
          renewable resources with the goal of increasing their existing  
          level of renewable resources by one percent per year of  
          electricity sold until a 20 percent renewable resources  
          portfolio is achieved.  Like the RPS, AB 57's requirement to buy  
          renewable energy is limited by the availability of Public Goods  
          Charge funds to subsidize above-market costs.  AB 57's renewable  
          procurement requirements are not explicitly contingent on rating  
          agency decisions.

          In August 2002, in anticipation of AB 57 and the RPS, the CPUC  
          issued an interim procurement order requiring each IOU to buy  
          renewable energy to achieve the one percent annual increase  
          contemplated in the legislation.  The CPUC relied on its general  
          authority and the direction provided by Section 701.3 to require  
          the IOUs to procure renewable resources.  Non-creditworthy IOUs  
          were authorized to enter contracts in partnership with the  
          Department of Water Resources. While Pacific Gas and Electric's  
          (PG&E) renewable procurement relied on DWR credit backing,  
          Southern California Edison's (SCE) did not.

          SB 1078, which took effect January 1, 2003, prohibits the CPUC  
          from requiring an IOU to conduct procurement to fulfill the  
          renewable portfolio standard until at least two "major rating  
          agencies" give it an investment grade credit rating.  PG&E and  
          SCE don't meet this condition currently.  It is unlikely PG&E  
          will meet this condition until some time after its bankruptcy  
          reorganization is resolved, which may result in a delay of its  
          implementation of the RPS. 

          According to the author, the purpose of the RPS is undermined by  
          making its implementation contingent on the decisions of credit  
          rating agencies.  This bill corrects that problem and allows  
          renewable procurement to proceed on terms which are reasonable  
          and acceptable to the buyer, the seller and the CPUC.

                                       COMMENTS
           
           Does an IOU need an investment grade credit rating to buy  










          renewable energy?   While the credit standing of a utility is  
          clearly an important factor in renewable procurement, as in  
          other aspects of its operations, it is unclear why renewable  
          procurement should be subject to a different standard than other  
          aspects of utility procurement or other regulated expenditures.

          It is possible for a sub-investment grade IOU to buy renewable  
          energy, as evidenced by SCE's ability to comply with the recent  
          CPUC order based on its current credit rating, which has not yet  
          returned to investment grade.

          An IOU must buy enough electricity to serve its customers.  The  
          RPS credit standard in current law does not change that fact, it  
          only sets a higher threshold for renewable procurement, which  
          places renewable resources at a disadvantage to non-renewable  
          resources.  An IOU that fails to buy renewable resources under  
          the RPS isn't relieved of its obligation to serve its customers  
          - it must buy non-renewable power instead.




































                                       POSITIONS
           
           Sponsor:
           
          Author

           Support:
           
          Independent Energy Producers (if amended)
          Office of Ratepayer Advocates
          Southern California Edison
          The Utility Reform Network

           Oppose:
           
          None on file

          




































          Lawrence Lingbloom 
          SB 67 Analysis
          Hearing Date:  April 8, 2003