Existing law requires the Public Utilities Commission to adopt a process for each load-serving entity to file an integrated resource plan, and a schedule for periodic updates to the plan to ensure that load-serving entities meet specified requirements. Existing law requires each load-serving entity to prepare and file an integrated resource plan consistent with certain requirements on a time schedule directed by the commission and subject to commission review.

This bill would provide that, for a load-serving entity that is electrical cooperative, the above requirements only apply if the electrical cooperative has an annual electrical demand exceeding 700 gigawatthours, as determined on a 3-year average commencing January 1, 2013.

Existing law requires the Public Utilities Commission to adopt a process for each load-serving entity to file an integrated resource plan, and a schedule for periodic updates to the plan to ensure that load-serving entities meet specified requirements. Existing law requires each load-serving entity to prepare and file an integrated resource plan consistent with certain requirements on a time schedule directed by the commission and subject to commission review.

This bill would provide that, for a load-serving entity that is electrical cooperative, the above requirements only apply if the electrical cooperative has an annual electrical demand exceeding 700 gigawatthours, as determined on a 3-year average commencing January 1, 2013.

Existing law requires the Public Utilities Commission to adopt a process for each load-serving entity to file an integrated resource plan, and a schedule for periodic updates to the plan to ensure that load-serving entities meet specified requirements. Existing law requires each load-serving entity to prepare and file an integrated resource plan consistent with certain requirements on a time schedule directed by the commission and subject to commission review.

This bill would provide that, for a load-serving entity that is electrical cooperative, the above requirements only apply if the electrical cooperative has an annual electrical demand exceeding 700 gigawatthours, as determined on a 3-year average commencing January 1, 2013.

Existing law requires the Public Utilities Commission to adopt a process for each load-serving entity to file an integrated resource plan, and a schedule for periodic updates to the plan to ensure that load-serving entities meet specified requirements. Existing law requires each load-serving entity to prepare and file an integrated resource plan consistent with certain requirements on a time schedule directed by the commission and subject to commission review.

This bill would provide that, for a load-serving entity that is electrical cooperative, the above requirements only apply if the electrical cooperative has an annual electrical demand exceeding 700 gigawatthours, as determined on a 3-year average commencing January 1, 2013.

CONCURRENCE IN SENATE AMENDMENTS

CSA1 Bill Id:AB 759

Author:(Dahle)

As Amended Ver:June 13, 2017

Majority vote

Original Committee Reference: U. & E.

SUMMARY: Exempts electrical cooperatives from the requirement to submit an integrated resource plan (IRP) to the California Public Utilities Commission (CPUC) if the cooperative has an annual electrical demand less than 700 gigawatt hours (GWh), as defined.

The Senate amendments were technical, grammatical changes only.

EXISTING LAW:

1. Defines "electrical cooperative" as a private corporation organized for transmitting or distributing electricity exclusively to its stockholders. (Public Utilities Code Section 2776)
2. Subjects an electrical cooperative to the requirements of the Public Utilities Act, except where specified. (Public Utilities Code Section 2778)
3. Defines "load-serving entity" as any electrical corporation, electrical service provider, or community choice aggregator, but specifically exempts publicly-owned utilities (POUs), the State Water Resources Development System, and customer-side generators. (Public Utilities Code Section 380)
4. Requires the CPUC to adopt a process for each load-serving entity to file an IRP to ensure they each meet the greenhouse gas (GHG) emissions reduction targets for the electricity sector; procure at least 50% eligible renewable energy resources by December 31, 2030; and meet other goals and obligations. (Public Resources Code Section 454.52)
5. Requires each load-serving entity to file an IRP with the CPUC for review. (Public Resources Code Section 454.52 [b][1])

FISCAL EFFECT: According to the Senate Appropriations Committee, pursuant to Senate Rule 28.8, negligible state costs.

COMMENTS:

According to the author, there are currently three electrical cooperatives based in California, serving approximately 15,000 members with a combined annual electrical demand of less than 350 GWh. This bill seeks to apply the same annual electrical demand threshold to electrical cooperatives as it applies to POUs for exemption from filing IRPs.

SB 350 (De León, Chapter 547, Statutes of 2015), required electrical entities to develop IRPs for CPUC or California Energy Commission (CEC) review. The IRPs are intended to provide a comprehensive plan for electricity procurement in order to meet the goal of achieving a 40% reduction in GHG emissions below 1990 levels by 2030. Investor-owned utilities (IOUs) and other electrical corporations governed by the CPUC submit their IRPs to the CPUC. POUs with annual loads of over 700 GWh are required to submit IRPs to the CEC. Small POUs are exempt from the IRP requirement.

Electrical cooperatives are small, rural electricity providers that are commonly member-owned and democratically controlled. Electrical cooperatives, POUs, and irrigation districts are owned by local governments or utility customers, and managed by locally elected officials or public employees who are responsible for setting rates. Electrical cooperatives function most similarly to POUs, but are defined as private corporations in statute. This bill treats electrical cooperatives the same as small POUs for the purposes of the IRP requirement.

The small POUs and electric cooperatives are not the only load-serving entities whose annual loads fall under the 700 GWh threshold. The Coalition for California Utility workers has opposed the bill, contending that all utilities in the state should be subject to the same rules; excluding one could lead to exclusion of others.

Analysis Prepared by: Laura McWilliams / U. & E. / (916) 319-2083 FN: 0001087

 THIRD READING  

Bill No: AB 759

Author:

:

Vote:

SENATE ENERGY, U. & C. COMMITTEE: 10-0, 6/6/17

AYES: Hueso, Morrell, Bradford, Cannella, Hertzberg, Hill, McGuire, Skinner, Vidak, Wiener

NO VOTE RECORDED: Stern

SENATE APPROPRIATIONS COMMITTEE: Senate Rule 28.8

ASSEMBLY FLOOR: 76-0, 5/4/17 (Consent) - See last page for vote

SUBJECT:

SOURCE: Golden State Power Cooperative

DIGEST:

This bill, in effect, exempts electrical cooperatives from the requirement to prepare and submit an integrated resources plan to the California Public Utilities Commission (CPUC).

ANALYSIS:

Existing law:

1. Defines an “electrical cooperative” as any private corporation or association organized for the purposes of transmitting or distributing electricity exclusively to its stockholders or members at cost. (Public Utilities Code §2776)
2. Subjects an electrical cooperative to the requirements of the Public Utilities Act, except where specified. (Public Utilities Code §2778)
3. Defines “load-serving entity” to mean an electrical corporation, electric service provider or community choice aggregator. (Public Utilities Code §380(k))
4. Requires the CPUC to adopt a process for each load-serving entity to file an integrated resource plan (IRP) to ensure they each meet the greenhouse gas (GHG) emissions reduction targets for the electricity sector; procure at least 50 percent eligible renewable energy resources by December 31, 2030; and meet other goals and obligations. (Public Resources Code §454.52)
5. Requires each load-serving entity to submit an IRP to the CPUC for review.

This bill limits the requirement to prepare and submit and IRP to only those electrical cooperatives that have an annual electrical demand exceeding 700 gigawatt hours.

Background

Load-serving Entities: IOUs, ESPs and CCAs...and Electrical Cooperatives. Several types of entities provide electricity service in California. Municipal utilities, also known as publicly owned utilities (POUs), such as the Los Angeles Department of Water and Power, provide electricity service within defined territories under the governance of locally elected officials. Several other types of entities, referred to in statute as load-serving entities, also provide electric service. California’s load-serving entities include:

• Investor-owned utilities (IOUs): privately owned electrical corporations, such as Southern California Edison, that provide monopoly services in distinct, defined geographic territories.
• Electric service providers (ESPs) provide electricity to end-use customers who choose the services of the ESP instead of the incumbent IOU. An ESP uses the transmission and distribution infrastructure of the IOU to deliver electricity to the customer.
• Community Choice Aggregators (CCAs) are programs, such as Marin Clean Energy, by which local governments choose to buy or generate electricity on behalf of local residents while using the incumbent IOU’s transmission and distribution infrastructure.

In 2015, the Legislature passed SB 350 (De León, Chapter 547). The bill established new renewable energy procurement requirements. As modified by SB 350, statute requires the CPUC to establish a process for each load-serving entity—including each electrical cooperative—to file with the CPUC a regularly updated IRP that ensures the load-serving entities will meet certain goals, including GHG reductions and procurement of at least 50 percent of renewable resources by the year 2030. The CPUC is currently developing the IRP process applicable to load-serving entities.

SB 350 also requires the POUs to prepare IRPs. However, the requirement applies to those POUs with an annual electrical demand exceeding 700 gigawatt hours. This limitation recognizes the limited resources of the smallest POUs and the disproportionate burden IRP preparation would place upon them.

Currently, there are three electrical coops operating in rural California—Anza Electric Cooperative, Plumas Sierra Rural Electric Cooperative and Surprise Valley Electrification Corporation. Together, the coops serve about 15,000 members. According to the coops, there combined electrical demand is less than 350 gigawatt hours. The state’s total electrical demand is about 300,000 gigawatt hours [http://www.energy.ca.gov/almanac/electricity_data/total_system_power.html]. Traditionally, the CPUC has interpreted statutory requirements that apply to the IOU’s as applying to the electrical coops [See CPUC decision D. 04-01-050].

This bill applies to electrical coops the load threshold criterion that applies to municipal utilities. The practical effect would be to exempt the electrical cooperatives from the need to prepare IRPs.

As is the case with smaller POUs, it would be very costly and resource intensive for the electrical cooperatives to prepare and submit IRPs to the CPUC. Further, the procurement choices of the electrical cooperatives are largely inconsequential to the state’s GHG emissions and reliability goals. There is no compelling need to require the electrical cooperatives to prepare and submit IRPs to the CPUC.

Prior/Related Legislation

SB 350 (De León, Chapter 547, Statutes of 2015), among other things, increased the Renewable Portfolio Standard and directed the CPUC to develop a process by which load-serving entities submit IRPs to the CPUC for review or for certification.

FISCAL EFFECT: Appropriation: Fiscal Com.: Local:

SUPPORT: (Verified 6/26/17)

Golden State Power Cooperative (source)

Northern California Power Agency

OPPOSITION: (Verified 6/26/17)

Coalition of California Utility Employees

ARGUMENTS IN SUPPORT: According to the author:

Assembly Bill 759 recognizes the burdensome requirements of Senate Bill 350 on Electric Cooperatives and proposes to amend section 454.52 of the Public Utilities Code to apply the same annual electrical demand threshold to Electric Cooperatives as it applies to publicly-owned electric utilities.

ARGUMENTS IN OPPOSITION: The Coalition of California Utility Employees contend all utilities in the state should be subject to the same rules and that excluding electric cooperatives could lead exclusion of other load-serving entities.

ASSEMBLY FLOOR: 76-0, 5/4/17

AYES: Acosta, Aguiar-Curry, Arambula, Baker, Berman, Bloom, Bocanegra, Bonta, Brough, Burke, Caballero, Calderon, Cervantes, Chau, Chávez, Chen, Chiu, Choi, Chu, Cooley, Cooper, Cunningham, Dababneh, Dahle, Daly, Eggman, Flora, Fong, Frazier, Friedman, Gallagher, Eduardo Garcia, Gipson, Gloria, Gomez, Gonzalez Fletcher, Gray, Grayson, Harper, Holden, Irwin, Jones-Sawyer, Kalra, Kiley, Lackey, Levine, Limón, Low, Maienschein, Mathis, Mayes, McCarty, Medina, Melendez, Mullin, Muratsuchi, Nazarian, Obernolte, O'Donnell, Quirk, Quirk-Silva, Reyes, Ridley-Thomas, Rodriguez, Rubio, Salas, Santiago, Steinorth, Mark Stone, Thurmond, Ting, Voepel, Waldron, Weber, Wood, Rendon

NO VOTE RECORDED: Travis Allen, Bigelow, Cristina Garcia, Patterson

Prepared by:

6/30/17 13:26:17

**** END ****

SENATE COMMITTEE ON ENERGY, UTILITIES AND COMMUNICATIONS

Senator Ben Hueso, Chair

2017 - 2018 Regular

Bill No: AB 759 Hearing Date: 6/6/2017

SUBJECT: Electricity: electrical cooperatives: integrated resource plan

DIGEST: This bill, in effect, exempts electrical cooperatives from the requirement to prepare and submit an integrated resources plan to the California Public Utilities Commission (CPUC).

ANALYSIS:

Existing law:

1. Defines an “electrical cooperative” as any private corporation or association organized for the purposes of transmitting or distributing electricity exclusively to its stockholders or members at cost. (Public Utilities Code §2776)
2. Subjects an electrical cooperative to the requirements of the Public Utilities Act, except where specified. (Public Utilities Code §2778)
3. Defines “load-serving entity” to mean an electrical corporation, electric service provider or community choice aggregator. (Public Utilities Code §380(k))
4. Requires the CPUC to adopt a process for each load-serving entity to file an integrated resource plan (IRP) to ensure they each meet the greenhouse gas (GHG) emissions reduction targets for the electricity sector; procure at least 50 percent eligible renewable energy resources by December 31, 2030; and meet other goals and obligations. (Public Resources Code §454.52)
5. Requires each load-serving entity to submit an IRP to the CPUC for review.

This bill limits the requirement to prepare and submit and IRP to only those electrical cooperatives that have an annual electrical demand exceeding 700 gigawatt hours.

Background

Load-serving Entities: IOUs, ESPs and CCAs...and Electrical Cooperatives. Several types of entities provide electricity service in California. Municipal utilities, also known as publicly owned utilities (POUs), such as the Los Angeles Department of Water and Power, provide electricity service within defined territories under the governance of locally elected officials. Several other types of entities, referred to in statute as load-serving entities, also provide electric service. California’s load-serving entities include:

• Investor-owned utilities (IOUs): privately owned electrical corporations, such as Southern California Edison, that provide monopoly services in distinct, defined geographic territories.
• Electric service providers (ESPs) provide electricity to end-use customers who choose the services of the ESP instead of the incumbent IOU. An ESP uses the transmission and distribution infrastructure of the IOU to deliver electricity to the customer.
• Community Choice Aggregators (CCAs) are programs, such as Marin Clean Energy, by which local governments choose to buy or generate electricity on behalf of local residents while using the incumbent IOU’s transmission and distribution infrastructure.

In 2015, the Legislature passed SB 350 (De León, Chapter 547). The bill established new renewable energy procurement requirements. As modified by SB 350, statute requires the CPUC to establish a process for each load-serving entity—including each electrical cooperative—to file with the CPUC a regularly updated IRP that ensures the load-serving entities will meet certain goals, including greenhouse gas reductions and procurement of at least 50 percent of renewable resources by the year 2030. The CPUC is currently developing the IRP process applicable to load-serving entities.

SB 350 also requires the POUs to prepare IRPs. However, the requirement applies to those POUs with an annual electrical demand exceeding 700 gigawatt hours. This limitation recognizes the limited resources of the smallest POUs and the disproportionate burden IRP preparation would place upon them.

Currently, there are three electrical coops operating in rural California—Anza Electric Cooperative, Plumas Sierra Rural Electric Cooperative and Surprise Valley Electrification Corporation. Together, the coops serve about 15,000 members. According to the coops, there combined electrical demand is less than 350 gigawatt hours. The state’s total electrical demand is about 300,000 gigawatt hours.^[1] Traditionally, the CPUC has interpreted statutory requirements that apply to the IOU’s as applying to the electrical coops.^[2]

This bill would apply to electrical coops the load threshold criterion that applies to municipal utilities. The practical effect would be to exempt the electrical cooperatives from the need to prepare IRPs.

As is the case with smaller POUs, it would be very costly and resource intensive for the electrical cooperatives to prepare and submit IRPs to the CPUC. Further, the procurement choices of the electrical cooperatives are largely inconsequential to the state’s GHG emissions and reliability goals. There is no compelling need to require the electrical cooperatives to prepare and submit IRPs to the CPUC.

Prior/Related Legislation

SB 350 (De León, Chapter 547, Statutes of 2015), among other things, increased the Renewable Portfolio Standard and directed the CPUC to develop a process by which load-serving entities submit IRPs to the CPUC for review or for certification.

FISCAL EFFECT: Appropriation: No Fiscal Com.: Yes Local: No

SUPPORT:

Golden State Power Cooperative (Source)

Northern California Power Agency

OPPOSITION:

Coalition of California Utility Employees

ARGUMENTS IN SUPPORT: According to the author:

Assembly Bill 759 recognizes the burdensome requirements of Senate Bill 350 on Electric Cooperatives and proposes to amend section 454.52 of the Public Utilities Code to apply the same annual electrical demand threshold to Electric Cooperatives as it applies to publicly-owned electric utilities.

ARGUMENTS IN OPPOSITION: The Coalition for California Utility Workers contend all utilities in the state should be subject to the same rules and that excluding electric cooperatives could lead exclusion of other load-serving entities.

-- END --

1. http://www.energy.ca.gov/almanac/electricity_data/total_system_power.html ↑

2. See CPUC decision D. 04-01-050. ↑

Date of Hearing: April 26, 2017

ASSEMBLY COMMITTEE ON APPROPRIATIONS

Lorena Gonzalez Fletcher, Chair

ABPCA Bill Id:AB 759

Author:(Dahle) – As Introduced Ver:February 15, 2017

Urgency: No State Mandated Local Program: No Reimbursable: No

SUMMARY:

This bill exempts electrical cooperatives from the requirement to submit an integrated resource plan (IRP) to the Public Utilities Commission (PUC) if the cooperative has an annual electrical demand under 700 gigawatthours (GWh), as defined.

FISCAL EFFECT:

Minor, if any additional PUC costs.

COMMENTS:

1. Purpose. According to the author, there are currently 3 electrical cooperatives based in California, serving approximately 15,000 members with a combined annual electrical demand of less than 350 gigawatt hours. This bill applies the same annual electrical demand threshold to electrical cooperatives as it applies to POU’s to lessen the burden on small utilities.
2. Background. SB 350 (De León), Chapter 737, Statutes of 2015, required electrical entities to develop IRPs for PUC or California Energy Commission (CEC) approval, by 2019. The IRPs are intended to provide a comprehensive plan for electricity procurement in order to meet the goal of achieving a 40 % reduction in greenhouse gas (GHG) emissions below 1990 levels by 2030. Generally, Investor-owned utilities (IOUs) and other electrical corporations governed by the PUC submit their IRPs to the PUC. Publicly-owned utilities (POUs) with annual loads of over 700 Gwh are required to submit IRPs to the CEC. Small POUs are exempt from the IRP requirement.
3. Electrical Cooperatives. Electrical cooperatives are small, rural electricity providers that are commonly member-owned and democratically controlled. Electrical cooperatives, publicly owned utilities (POUs), and irrigation districts are either local governments or owned by utility customers, and managed by locally elected officials or public employees who are responsible for setting rates. Electrical cooperatives function most similarly to POUs, but are defined as private corporations in statute. This bill treats electrical cooperatives the same as small POUs for the purposes of the IRP requirement.

Analysis Prepared by: Jennifer Galehouse / APPR. / (916) 319-2081

Date of Hearing: March 29, 2017

ASSEMBLY COMMITTEE ON UTILITIES AND ENERGY

Chris Holden, Chair

ABPCA Bill Id:AB 759 (

Author:Dahle) – As Introduced Ver:February 15, 2017

SUBJECT: Electricity: electrical cooperatives: integrated resource plan

SUMMARY: Exempts electrical cooperatives from the requirement to file an integrated resource plan (IRP) with the California Public Utilities Commission (CPUC) if annual electrical demand is under 700 gigawatt hours (GWh), as determined on a three-year average beginning on January 1, 2013.

EXISTING LAW:

1. Requires the CPUC to ensure a reliable electricity supply while balancing optimal renewable energy integration with cost-effectiveness, and to direct investor-owned utilities (IOUs) to include, as part of procurement planning, a strategy for procuring best-fit and least-cost resources to satisfy the CPUC’s portfolio needs. (Public Utilities Code § 454.51)
2. Requires the CPUC to adopt a process for each load-serving entity (LSE) to file an IRP, ensuring LSEs meet state GHG emission reduction targets and procure at least 50 percent renewable energy resources by December 31, 2030. (Public Utilities Code §454.52)
3. Defines “load-serving entity” as any electrical corporation, electrical service provider, or community choice aggregator, but specifically exempts publicly-owned utilities (POUs), the State Water Resources Development System, and customer-side generators. (Public Utilities Code §380)
4. Requires each POU with an annual electrical demand above 700 GWh, as determined on a three-year average beginning on January 1, 2013, to adopt and regularly update an IRP, to be reviewed by the CEC. (Public Utilities Code §9621)
5. Defines “electrical cooperative” as a private corporation organized for transmitting or distributing electricity exclusively to its stockholders. (Public Utilities Code §2776)

FISCAL EFFECT: This bill is keyed fiscal and will be referred to the Appropriations Committee for its review of the fiscal effect of this bill.

BACKGROUND:

SB 350 (De León, 2015) mandated electrical entities to develop IRPs, pursuant to CPUC or CEC approval, by 2019. The IRP introduces a new statewide scale to resource planning in order to meet the goal of achieving a 40% reduction in greenhouse gas (GHG) emissions below 1990 levels by 2030. IRPs are intended to provide a comprehensive plan for electricity procurement, seeking to frame energy priorities in terms of the state’s GHG targets, renewable portfolio standards, and energy efficiency goals.

California’s electricity is served by a diverse array of LSEs. The GHG emissions reductions sought from SB 350 results in the CPUC, CEC, and CARB coordinating resource decisions across all LSEs, and across the various resource programs already in effect.^[1] Prior to SB 350, LSEs submitted long-term procurement plans (LTPPs) to the CPUC, which evaluated the need for new resources to meet system and local area reliability needs. The CPUC established up-front standards for the LTPPs, pursuant to AB 57 (Wright, 2002), and directed IOUs to procure best-fit and least-cost resources. In establishing the IRPs, SB 350 replaced the LTPP process in favor of comprehensive plans that ensure LSEs:^[2]

1. Meet the GHG emissions reduction targets established by CARB for the electricity sector and that reflect the electricity sector’s percentage in achieving the economy-wide GHG emissions reductions of 40 percent from 1990 levels by 2030;
2. Procure at least 50 percent eligible renewable energy resources by 2030;
3. Double the energy efficiency savings in electricity and natural gas of retail customers through energy efficiency and conservation by 2030;
4. Enhance transportation electrification efforts;
5. Enable each electrical corporation to fulfill its obligations to serve its customers at just and reasonable rates, including minimizing impacts on ratepayers’ bills;
6. Ensure system and local reliability;
7. Strengthen diversity, sustainability, and resilience of the bulk transmission and distribution systems and local communities;
8. Enhance distribution system and demand-side energy management; and
9. Minimize localized air pollutants and other GHG emissions, with early priority on disadvantaged communities.

COMMENTS:

1. Author’s Statement. According to the author’s office, “SB 350 passed the Legislature in 2015 and it required all load-serving entities to prepare and provide to the California Public Utilities Commission for review and approval an Integrated Resource Plan that identifies the entity’s energy procurement program. Electrical cooperatives are small member-owned entities that provide electric service to their members living in rural communities that were previously unserved. There are currently 3 electrical cooperatives based in California, two of them in my Assembly District, serving approximately 15,000 members with a combined annual electrical demand of less than 350 gigawatt hours. AB 759 recognizes the burdensome IRP requirements of SB 350 on Electrical Cooperatives and proposes to amend the law to apply the same annual electrical demand threshold to Electrical Cooperatives as it applies to POU’s and lessen the burden on these small utilities.”
2. Diversity of Electrical Entities in California. This bill exempts electrical cooperatives (“co-ops”) from filing IRPs. Electrical co-ops are small, rural electricity providers that are commonly member-owned and democratically controlled. Electrical co-ops, POUs, and irrigation districts are owned by local governments or utility customers, and managed by locally elected officials or public employees who are responsible for setting rates. While electrical co-ops function most similarly to POUs, they are not defined as such in statute; rather, they are defined as private corporations. Electrical corporations are owned by shareholders and investors, and are regulated by the CPUC.  Investor-owned-utilities (IOUs) such as Southern California Edison (SCE) and Pacific Gas & Electric (PG&E) are electrical corporations.
3. An Issue of Size. In the original IRP legislation, the POUs successfully argued that POUs below an annual load threshold of 700 GWh have limited staff and resources to develop IRPs and to participate in the complicated and lengthy CPUC proceedings. Moreover, it was opined that development of IRPs and being party to CPUC proceedings were not costs these smaller utilities could absorb. Rather, these small POUs would have to raise rates in order to undertake IRPs. Given their small size, it was opined that the GHG emission reductions achieved from the small POUs participating in an IRP were nominal compared to the projected burden to ratepayers. The Legislature acknowledged this burden by excluding small POUs from the IRP mandate in SB 350.

Electrical co-ops are also small. For the three electrical co-ops based in California,^[3] their combined annual electrical demand is less than 350 GWhs, approximately 0.1% of California’s electrical sales. For comparison, the combined annual load of the investor-owned-utilities^[4] and the two POUs in Los Angeles and Sacramento^[5] account for approximately 90% of California’s total load. For electrical co-ops, the smaller size comes with smaller budgets and staff, similar to the small POUs currently exempt from the IRP. However, no such IRP exemption was given to the electrical co-ops.

1. A Matter of Definitions. The planning mandate in current law applies to LSEs and defines them as any “electrical corporation, electrical service provider, or community choice aggregator.”^[6] Initial reading of this statute might suggest electrical co-ops should therefore be exempt from the IRP filing, as they are not explicitly listed. However, administrative precedent of the CPUC defines LSEs to include electrical co-ops.^[7] Additionally, statute defines electrical co-ops as “any private corporation…”.^[8] As a result, the CPUC has included electrical co-ops in their IRP rulemaking.^[9]

REGISTERED SUPPORT / OPPOSITION:

Support

Golden State Power Cooperative (Sponsor)
Northern California Power Agency

Opposition

None on file.

Analysis Prepared by: Laura McWilliams / U. & E. /

1. For example energy efficiency, demand response, renewable portfolio standard (RPS), and storage ↑

2. CPUC R. 16-02-007 ↑

3. Anza Electric Cooperative, Plumas Sierra Rural Electric Cooperative, and Surprise Valley Electrification Corporation ↑

4. Including CCAs ↑

5. Los Angeles Department of Water and Power (LADWP) and Sacramento Municipal Utility District ↑

6. PUC §380 ↑

7. CPUC D. 04-01-050 ↑

8. PUC §2776 ↑

9. CPUC R. 16-02-007; see Appendix A of: http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M158/K663/158663325.PDF ↑