HomeMy WebLinkAbout _ 4.5(a)--Redding RPS Procurement Plan and Enforcement Program
CITY OF REDDING
REPORT TO THE CITY COUNCIL
Recommendation
Approve Version 6 of the Redding Electric Utility’s Renewables Portfolio Standard Procurement
Plan and Enforcement Program (RPS Plan) procedure RPS-001, updating language to Section
3.2(C), Cost Limitations for Expenditures, to provide added assurance of rate predictability and
stability for Redding Electric Utility customers.
Fiscal Impact
No immediate fiscal impact is associated with adopting the attached revised Renewables
Portfolio Standard Procurement Plan and Enforcement Program (RPS Plan). However, the
updated language to Section 3.2(C), Cost Limitations for Expenditures, provides added assurance
of rate predictability and stability for Redding Electric Utility (REU) customers.
Alternative Action
The City Council (Council) could suggest additional modifications to the attached revised RPS
Plan and request staff to return the modified version to Council for consideration at a later date.
Background/Analysis
Senate Bill 100 required California electric utilities to acquire 60 percent of their annual energy
needs from renewable resources by 2030. Furthermore, Senate Bill 100 included a policy
statement that eligible renewable energy resources and zero-carbon resources should comprise
100 percent of retail sales of electricity to California end-use customers by December 31, 2045.
MEETING DATE: March 21, 2023
ITEM NO. 4.5(a)
FROM:
***APPROVED BY***
nzettel@cityofredding.org
btippin@cityofredding.org
SUBJECT: 4.5(a)--Redding RPS Procurement Plan and Enforcement Program
Nick Zettel, Director of
Redding Electric Utility
Report to Redding City Council March 16, 2023
Re: 4.5(a)--Redding RPS Procurement Plan and Enforcement Program Page 2
Since passage of earlier legislation requiring procurement of renewable energy, t he California
Energy Commission (CEC) developed procedures for enforcement of the RPS Plan for publicly
owned utilities. As part of that enforcement authority, on June 12, 2013, the CEC adopted
Enforcement Procedures for local, publicly-owned electric utilities (RPS Enforcement
Regulation). The RPS Enforcement Regulations require utilities to adopt RPS Plans and file
them with the CEC. On October 15, 2013, the City adopted an RPS Plan – when substantive
changes are made to the RPS Plan, REU provides continual updates.
As required by regulations, the CEC uses Renewable Energy Credits (RECs) to track compliance
with RPS regulations. One REC represents one megawatt-hour (MWh) of electricity generated
from a renewable energy source. In 2022, REU staff was notified by the CEC that over 121,000
of its RECs that were retired for the 2020 Compliance Period were deemed ineligible due to an
administrative error in the CEC’s online reporting tool. Staff has continued working diligently
with utility partners to appeal the CEC’s decision, which is currently pending. In response to the
CEC’s current conclusion, REU has evaluated its available resource options with the goal of
avoiding any potential undue cost burden to ratepayers.
The RPS Enforcement Regulations allow for exemptions to avoid disproportionate rate impacts
on utility customers. Updated language has been added to the RPS Plan’s Optional Compliance
Measure - Cost Limitation section to clarify the characterization and applicability of Cost
Limitation criteria. The proposed updates to the RPS Plan ensure REU can leverage those
Optional Compliance Measures in the event a situation potentially warrants doing so. REU staff
is optimistic about reaching a positive outcome with the CEC that will not require the use of the
Cost Limitation provision; however, it is important to ensure the option is available in the event
it needs to be exercised.
Environmental Review
This is not a project defined under California Environmental Quality Act (CEQA), and no further
action is required.
Council Priority/City Manager Goals
• This agenda item is a routine operational item
Attachments
RPS-001 RPS Policies and Procedures 3-21-2023
DRAFT Redding RPS Procurement Plan & Enforcement Program 3-21-23 (Redlines)
1
Procedure No:
RPS-001
Version:
6
Approval Date:
3/21/2023 RPS Policies &
Procedures Effective Date: March 21, 2023
Document Owner: Lisa Casner
REDDING ELECTRIC UTILITY
Resources Division
RPS-001 Renewables Portfolio
Standard Enforcement Program and
Procurement Plan
Reviewed By:
Lisa Casner (Electric Manager – Resources), Nicholas Zettel (Electric Utility
Director)
Adopted By: Redding City Council
Date: March 21, 2023
2
TABLE OF CONTENTS
1. Introduction ........................................................................................................... 3
2. RPS Procurement Plan ............................................................................................ 3
2.1 Purpose .................................................................................................................. 3
2.2 Compliance Periods ............................................................................................... 4
2.3 Portfolio Content Categories (RPS Enforcement Regulation § 3203) ................... 6
2.4 Procurement Requirements (RPS Enforcement Regulation § 3204) .................... 9
2.5 Redding’s Plan for RPS Compliance ..................................................................... 11
3. RPS Enforcement Program .................................................................................... 11
3.1 Enforcement Policy .............................................................................................. 11
3.2 Optional Compliance Measures .......................................................................... 12
4. Review and Updating Requirements .................................................................... 14
3
1. Introduction
Senate Bill 2 in the First Extraordinary Session (SBX1-2)1 defines the California Renewables
Portfolio Standard (RPS) and imposes minimum renewable energy procurement targets for
all retail sellers and publicly-owned utilities (POUs), including the City of Redding (Redding).
SBX1-2 authorized the California Energy Commission (CEC) to develop procedures for
enforcement of the RPS for POUs. As part of that enforcement authority, the CEC adopted
“Enforcement Procedures for the Renewables Portfolio Standard for Local, Publicly-Owned
Electric Utilities” (RPS Enforcement Regulations) 2 and updated regulations were
subsequently adopted in 2021. This document describes Redding’s RPS Procurement and
Enforcement Plan, as required by the Public Utility Code (PUC) section 399.30(a), which must
be approved by the Redding City Council.
1.1 Utility Code
Redding maintains compliance with a multitude of state laws that govern certain aspects of
utility energy portfolio requirements. These include the following code sections, which
relate to California’s Renewable Portfolio Standard:
• Renewable Portfolio Standard requirement PUC § 399.30(a)
• Compliance Period and Procurement Targets PUC § 399.30(b) and (c)
• Portfolio Content Categories PUC § 399.16(b) and (c)
• RPS POU Compliance PUC § 399.30(n)
• Optional Compliance Measures PUC § 399.30(d) and PUC § 399.33
2. RPS Procurement Plan
2.1 Purpose
The purpose of the RPS Procurement Plan is to identify the policies and procedures for
Redding to meet the RPS requirements and any future adopted state-defined renewable
goals. SB350 was signed by Governor Brown in 2015, mandating that 50 percent (50%) of
retail sales must be served by RPS eligible resources by 2030. SB350 also mandated Redding
to produce an Integrated Resource Plan that will guide the Procurement Plan as allowed by
PUC section 399.17(d). In 2018, SB100 was signed by Governor Brown, which increased the
RPS goals to 60% by 2030, and in 2021, the CEC approved updates to the RPS regulations.
1 SBX1-2 (Simitian, Stats. 2011, Ch. 1) was signed by California’s Governor on April 12, 2011.
2 The CEC adopted the RPS Enforcement Regulations on June 12, 2013, in Order No. 13 -0612-5.
4
2.2 Compliance Periods
Compliance periods are defined by multi-year percentage targets mandated by law.
Compliance Periods 1, 2, and 3 have passed; however, they are included below for reference:
A. Compliance Period 1
(1) During Compliance Period 1, January 1, 2011, to December 31, 2013, Redding
shall procure, at a minimum, renewable energy resources equivalent to an
average of 20 percent of retail sales over the three (3) years of the compliance
period.
Expressed as:
EP2011 + EP2012 + EP2013 ≥ .20 (RS2011 + RS2012 + RS2013)
Where:
RSX = total retail sales made by Redding for the specified year X.
EPX = electricity products procured for the specified year X; this may include
excess procurement and historic carryover that the POU has chosen to apply
to the compliance period containing year X.
B. Compliance Period 2
(1) For Compliance Period 2, January 1, 2014, to December 31, 2016, Redding shall
procure renewable energy resources to meet or exceed the sum of 20 percent
of retail sales for each of 2014 and 2015, and 25 percent of retail sales for
2016.
Expressed as:
EP2014 + EP2015 + EP2016 ≥ 0.20 (RS2014) + 0.20 (RS2015) + 0.25 (RS2016)
C. Compliance Period 3
(1) For Compliance Period 3, January 1, 2017, to December 31, 2020, Redding shall
procure renewable energy resources to meet or exceed 33 percent of retail
sales by 2020. During the intervening years of Compliance Period 3, Redding
shall increase procurement to reflect an imputed compliance obligati on.
Expressed as:
(EP2017 + EP2018 + EP2019 + EP2020)
≥ 0.27 (RS2017) + 0.29 (RS2018) + 0.31 (RS2019) + 0.33 (RS2020)
5
D. Compliance Period 4
(1) For the compliance period beginning January 1, 2021, and ending December
31, 2024, Redding shall demonstrate it has procured electricity products
within that period sufficient to meet or exceed the sum of 35.75 percent of its
2021 retail sales, 38.50 percent of its 2022 retail sales, 41.25 percent of its
2023 retail sales, and 44.00 percent of its 2024 retail sales.
Expressed as:
(EP2021 + EP2022 + EP2023 + EP2024)
≥ 0.3575 (RS2021) + 0.3850 (RS2022) + 0.4125 (RS2023) + 0.4400 (RS2024)
Redding may not apply Portfolio Content Category 3 RECs in excess of the
maximum limit calculated in section 3204 (c)(3)(A) toward its RPS
procurement target for this period.
E. Compliance Period 5
(1) For the compliance period beginning January 1, 2025, and ending December
31, 2027, Redding shall demonstrate it has procured electricity products
within that period sufficient to meet or exceed the sum of 46.00 percent of its
2025 retail sales, 50.00 percent of its 2026 retail sales, and 52.00 percent of its
2027 retail sales.
Expressed as:
EP2025 + EP2026 + EP2027
≥ 0.4600(RS2025) + 0.5000(RS2026) + 0.5200(RS2027)
Redding may not apply Portfolio Content Category 3 RECs in excess of the
maximum limit calculated in section 3204 (c)(3)(A) toward its RPS
procurement target for this period.
F. Compliance Period 6
(1) For the compliance period beginning January 1, 2028, an d ending December
31, 2030, Redding shall demonstrate it has procured electricity products
within that period sufficient to meet or exceed the sum of 54.67 percent of its
2028 retail sales, 57.33 percent of its 2029 retail sales, and 60.00 percent of its
2030 retail sales.
Expressed as:
EP2028 + EP2029 + EP2030
≥ 0.5467(RS2028) + 0.5733(RS2029) + 0.6000(RS2030)
6
Redding may not apply Portfolio Content Category 3 RECs in excess of the
maximum limit calculated in section 3204 (c)(3)(A) toward its RPS
procurement target for this period.
G. Compliance Periods Beginning on and after January 1, 2031
(1) Compliance periods beginning on and after January 1, 2031, shall be three
years in length starting on January 1 and ending on December 31. For each
compliance period beginning on or after January 1, 2031, Redding shall
demonstrate it has procured electricity products within the compliance period
sufficient to meet or exceed an average of 60.00 percent of Redding’s retail
sales over the three calendar years of the compliance period.
Expressed as:
EPX1 + EPX2 + EPX3 ≥ 0.6000 (RSX1) + 0.6000 (RSX2) + 0.6000 (RSX3)
Redding may not apply Portfolio Content Category 3 RECs in excess of the
maximum limit calculated in section 3204 (c)(3)(A) toward its RPS
procurement target for this period.
2.3 Portfolio Content Categories (RPS Enforcement Regulation § 3203)
In addition to meeting the renewable energy procurement target, the RPS established
Portfolio Content Categories (PCC) that outline the eligible renewable energy resource
products that must be procured to ensure compliance with minimum and maximum values
as summarized in Table 2.
A. PCC1: (RPS Enforcement Regulations § 3203(a))
(1) PCC1 electricity products must be bundled at the time of procurement to be
classified as PCC1, and the POU may not resell the underlying electricity from the
electricity product back to the eligible renewable energy resource from which the
electricity product was procured. The electricity products must be generated by
an eligible renewable energy resource that is interconnected to a transmission
network within the Western Electricity Coordinating Council (WECC) service
territory. For purposes of this section 3203, the first point of interconnection to
the WECC transmission grid is the substation, or, where generation tie lines
interconnect from the eligible renewable energy resource to the network
transmission grid.
(a) Electricity products must be generated by an eligible renewable energy
resource that has its first point of interconnection within the metered
boundaries of a California balancing authority area, or
7
(b) Electricity products must be generated by an eligible renewable energy
resource that has its first point of interconnection to an electricity distribution
system used to serve end-users within the metered boundaries of a California
balancing authority area. For purposes of this section 3203, the first point of
interconnection to an electricity distribution system is within the service area
boundaries of a utility distribution company.
(c) Electricity products from the eligible renewable energy resource with a first
point of interconnection outside the metered boundaries of a California
balancing authority area must be scheduled into a California balancing
authority area without substituting electricity from another source. For
purposes of this section 3203, electricity generated by the eligible renewable
energy resource must be scheduled into a Californ ia balancing authority area
on an hourly or sub-hourly basis. The POU’s governing board, or other
authority as delegated by the POU governing board, must have approved an
agreement before the electricity is generated to schedule the electricity from
the eligible renewable energy resource into the California balancing authority
area on an hourly or sub-hourly basis. If there is a difference between the
amount of electricity generated within an hour and the amount of electricity
scheduled into a California balancing authority area within that same hour,
only the lesser of the two amounts shall be classified as PCC1.
(d) Electricity products must be subject to an agreement between a California
balancing authority area and the balancing authority in which the eligible
renewable energy resource is located and executed before the product is
generated to dynamically transfer electricity from the eligible renewable
energy resource into the California balancing authority area.
(3) Electricity products originally qualifying in PCC1 that do not meet the criteria of
section 3203 (a)(2)(A) and are resold – (D) shall not be counted in PCC1.
B. PCC2: (RPS Enforcement Regulations § 3203(b))
(1) PCC2 electricity products must be generated by an eligible renewable energy
resource that is interconnected to a transmission network within the WECC
service territory, and the electricity must be matched with incremental electricity
that is scheduled into a California balancing authority area.
(2) PCC2 electricity products must be bundled when procured and must meet all of
the following criteria:
(a) The first point of interconnection to the WECC transmission grid for both the
eligible renewable energy resource and the resource providing the
8
incremental electricity must be located outside the metered boundaries of a
California balancing authority area.
(b) The incremental electricity used to match the electricity from the eligible
renewable energy resource must be incremental to the POU. For purposes of
this section 3203, “incremental electricity” means electricity that is
generated by a resource located outside the metered boundaries of a
California balancing authority area; prior to the date of contract or
ownership agreement, electricity is not in the portfolio of the POU claiming
the electricity products for RPS compliance from eligible renewable energy
resources with which the incremental electricity is being matched; is
executed by the POU, or other authority, as delegated by the POU governing
board.
(c) The governing board, or other authority as delegated by the governing board,
executes the contract or ownership agreement for the incremental electricity
at the same time or after the contract or ownership agreement for the
electricity products from the eligible renewable energy resource is executed.
(d) The incremental electricity must be scheduled into the California balancing
authority area within the same calendar year as the electricity from the eligible
renewable energy resource is generated.
(e) The electricity from the eligible renewable energy resource must be available
to be procured by the POU and may not be sold back to that resource.
C. PCC3: (RPS Enforcement Regulations § 3203(c))
All unbundled renewable energy credits and other electricity products procured from
eligible renewable energy resources located within the WECC transmission grid that
do not meet the requirements of either PCC1 or PCC2 fall within PCC3.
D. PCC0: (RPS Enforcement Regulations § 3202(a)(2))
(1) Any contract or ownership agreement originally executed prior to June 1, 2010,
shall count in full toward the procurement requirements if all of the following
conditions are met:
(a) The renewable energy resource met the Commission’s RPS eligibility
requirements that were in effect when the original procurement or ownership
agreement was executed.
9
(b) Any contract amendments or modifications occurring after June 1, 2010, do
not increase the nameplate capacity, expected quantities of annual
generation, or substitute a different renewable energy resource.
(c) If contract amendments or modifications after June 1, 2010, increase
nameplate capacity or expected quantities of annual generation, increase the
term of the contract, or substitute a different eligible renewable energy
resource, only the MWhs or resources procured prior to June 1, 2010, shall
count in full toward the RPS procurement targets. The remaining procurement
that is additional due to the amendment must be classified into a portfolio
content category and as long-term or short-term, and follow the portfolio
balance requirements and long-term procurement requirement in accordance
with RPS Enforcement Regulations section 3204 (c) and 3204 (d).
(d) The duration of the contract may be extended if the original contract specified
a procurement commitment of fifteen (15) years or more.
2.4 Procurement Requirements (RPS Enforcement Regulation § 3204)
A. RPS procurement targets for each compliance period
A POU shall demonstrate it has procured electricity products sufficient to meet or
exceed the procurement requirements for the respective compliance periods listed
below:
Table 1: RPS Renewable Requirement
To allow for market and load variations, Redding may procure additional RECs in each
Compliance Period above the values listed in Table 1.
B. Exemptions and Adjustments
1. Adjustment for Large Hydroelectric Generation
Consistent with RPS Enforcement Regulations § 3204(b)(8), from January 1, 2019,
through December 31, 2030, if Redding receives more than 40 percent (40%) of its
retail sales from large hydroelectric generation during a given year of a compliance
period, Redding is not required to procure electricity products that exceed the lesser
Compliance Period 4 CP 5 CP 6 CP 7
… 2021 2022 2023 2024 …2027 …2030 2031…
… 35.75% 38.5% 41.25% 44% 52% 60% 60%
10
of the portion of the POU’s retail sales unsatisfied by the POU’s large hydroelectric
generation, or the soft target for the relevant year of the compliance period.
2. Adjustment for Qualifying Gas-Fired Power Plant
If all requirements in RPS Enforcement § 3204(b)(11) are satisfied, Redding may
reduce the amount of eligible renewable energy resources that it procures for a
compliance period beginning January 1, 2025, if the gas-fired power plant is operating
at or below a 20 percent (20%) capacity factor on an annual average basis during a
given compliance period. This amount is calculated by the difference between the gas-
fired power plant’s actual generation for the compliance period if it had operated at
a 20 percent (20%) capacity factor on an annual average during the compliance
period. In order to participate, Redding was required to notify the CEC of its intent to
act pursuant to this exemption by April 1, 2019. Redding submitted its notification to
the CEC on March 12, 2019, and the CEC accepted it on July 31, 2019.
C. Portfolio Balance Requirements
Beginning in Compliance Period 4, at least seventy-five percent (75%) of Redding’s
RPS procurement shall be from PCC 1 contracts, with a maximum of 10 percent of
Redding’s RPS procurement from PCC 3 RECs (PUC section 399.16). There is no direct
restriction on the percentage of PCC 2.
REC
Classification
Compliance
Period 1
2011-2013
Compliance
Period 2
2014-2016
Compliance
Period 3
2017-2020
Compliance
Period 4
2021-2024
Compliance
Period 5
2025-2027
Compliance
Period 6
2027-2030
PCC 1 RECs
(Minimum) 50% 65% 75% 75% 75% 75%
PCC 2 RECs
(No Direct
Restriction)
n/a n/a n/a n/a n/a n/a
PCC 3 RECs
(Maximum) 25% 15% 10% 10% 10% 10%
PCC 0 Not subject to portfolio balancing requirements
Table 2: RPS Balancing Requirement
D. Long-Term Portfolio Requirement
For the compliance period beginning January 1, 2021, and each compliance period
thereafter, at least 65 percent of the electricity products applied toward the RPS
procurement target shall be from contracts of 10 years or more in duration or
ownership or ownership agreements for eligible renewable energy resources (PUC
section 399.13(b) and 399.30(d)).
11
Electricity products will be classified as long-term or short-term based on the
contracts, ownership, or ownership agreements through which they are procured.
For the purpose of this section 3204 (d) subdivision, long-term procurement refers
to procurement from long-term contracts (over ten years in duration), ownership, or
ownership agreements, subject to criteria outlined in section 3204 (d).
2.5 Redding’s Plan for RPS Compliance
In order to meet the RPS mandates, Redding plans to preserve its existing PCC0 resources,
carry forward excess procurement from one compliance period to the next, and look for
valuable opportunities to diversify and expand its RPS portfolio while protecting Redding’s
customers from excessive rate increases that could jeopardize economic growth and viability
within the City.
The Integrated Resource Plan (IRP) will be the guiding document and framework used for
future RPS energy procurement efforts. The IRP will be used as a procurement guide for RPS
resource quantity, timing, location, and generation profiles. The IRP is filed with the
California Energy Commission and will follow the required timely updates.
Redding plans to continue evaluating eligible renewable power resources and will initiate any
necessary procurement solicitations consistent with the IRP.
3. RPS Enforcement Program
3.1 Enforcement Policy
In compliance with the requirement for the governing board of a POU to adopt a program for
enforcement of the legislation prior to January 1, 2012, the Redding City Council passed
Resolution 2011-197 “Resolution of the City Council of the City of Redding to Revise the
Renewable Portfolio Standard for the City of Redding’s Electric System” on December 20, 2011.
Resolution 2011-197 adopted the following RPS targets:
• An average of 20 percent in 2011 through 2013;
• 25 percent by 2016; and
• 33 percent by 2020 and thereafter.
Resolution 2011-197 also adopted the following Enforcement Policies:
• Redding will make a reasonable effort in the context of Good Utility Practice to be in
compliance with the requirements of SBX1-2.
12
• Redding will report to the City Council on its status of compliance with SBX1-2 per PUC
section 399.13.
• Redding will notify the City Council of any potential for lack of compliance with the
requirements that may be considered for a notice of violation and penalty imposition.
• Redding will provide an explanation and analysis to the City Council on such potential
for lack of compliance, as well as a plan of corrective action and timeframe for
returning the City to compliant status.
The Redding City Council approved updated RPS goals on September 17, 2019 , due to the
passing of SB 100, which accelerated RPS goals previously established in SB 350 as follows:
• 44 percent by 2024;
• 52 percent by 2027;
• 60 percent by 2030 and thereafter.
The Redding City Council approved the updated RPS procurement plan on March 21, 2023,
modifying how Redding utilizes the plan’s Optional Compliance Measures.
3.2 Optional Compliance Measures
Specific optional compliance measures are permitted and are adopted by Redding and the
City Council. Redding adopts the following optional compliance measures, which may be
utilized in the event that factors beyond reasonable control interfere with its ability to meet
the procurement requirements set forth in § 3206 of the RPS Regulations.
A. Excess Procurement:
Redding shall be allowed to apply Excess Procurement from one compliance period to
subsequent compliance periods using the criteria outlined in § 3206(a)(1) of the RPS
Enforcement Regulations.
B. Delay of Timely Compliance:
Enforcement of timely compliance shall be waived if Redding demonstrates that any
of the conditions defined in RPS Enforcement Regulations § 3206(a)(2) are beyond the
control of Redding, and Redding would have met its RPS procurement requirements
but for the cause of delay.
13
C. Cost Limitations for Expenditures:
The City of Redding’s current RPS policy requires that Redding pursue target levels of
renewable purchases while ensuring that costs for renewable purchases do not result
in disproportionate rate impacts to customers. To ensure customers do not face a
disproportionate burden, Redding’s City Council has the authority to implement a
Cost Limitation, which may result in the temporary suspension of RPS compliance
activities.
In this section, Redding establishes a Cost Limitation on the procurement
expenditures for all eligible renewable energy resources used to comply with the RPS,
consistent with RPS Enforcement Regulations § 3206(a)(3). Potential reliance on this
provision for compliance will be consistent with the City’s Renewables Portfolio
Standard Procurement Plan and the schedule that satisfies the procurement
requirements set forth in Section 2.4 of this document.
The following circumstances may result in disproportionate rate impacts to REU
customers and may constitute cause for the application of the Cost Limitation
Optional Compliance Measure:
(1) An increase to the renewable energy procurement requirements for a given
compliance period, as set forth in Section 2.4, not based on a change in electric
retail sales, resulting in a deviation from Redding’s forecasted renewable energy
procurement requirement.
(2) Projected costs to meet renewable energy procurement requirements for a
given compliance period exceed the forecasted costs adopted in Redding’s
renewable energy procurement budget.
When estimating the considered RPS procurement expenditure , the following
costs will also be included:
(a) The costs associated with the energy, renewable attribute, firming and
shaping, and/or storage, as needed for intermittent resources; and
(b) The costs associated with the delivery of renewable energy.
In the event that renewable energy procurement requirements meet the threshold
for application of the Cost Limitation Optional Compliance Measure, Redding shall
review its RPS Procurement Plan to ensure that alternatives are not available that
would otherwise allow Redding to meet its RPS procurement requirement. Such
review shall include an evaluation of:
• current procurement commitments,
14
• planned procurements,
• long-term commitments, and
• the availability of alternative resources in other portfolio content categories.
Based on this review, Redding reserves the right to refrain from entering into new
contracts for renewable energy purchases that meet any of the exemptions listed in
its Cost Limitation provisions.
D. Portfolio Balance Requirement Reduction:
The Portfolio Balance Requirement shall be reduced if Redding demonstrates that any
of the conditions defined in RPS Enforcement Regulations § 3206(a)(4) are beyond the
control of Redding, and Redding would have met its Portfolio Balance Requirements
but for the cause of reduction.
4. Review and Updating Requirements (RPS Enforcement Regulations § 3205(a)
and (b))
Redding is required to complete an Integrated Resource Plan that will guide the Procurement
plan. Redding will provide the following notice regarding new or updated renewable energy
resources procurement and enforcement plans:
A. Renewable Energy Resources Procurement Plan
(1) Redding shall post notice in accordance with Chapter 9 (commencing with § 54950)
of Part 1, Division 2, Title 5 of the Government Code, whenever the City Council will
deliberate in public on the RPS Procurement Plan.
B. Enforcement Plan
(1) Redding shall provide notice regarding new or updated enforcement programs. The
enforcement program must be adopted at a publicly noticed meeting offering all
interested parties an opportunity to comment.
a. No less than 30 calendar days’ notice shall be given to the public of any
meeting held for purposes of adopting the enforcement program.
b. If the enforcement program is modified or amended, no less than 10 calendar
days’ notice shall be given to the public before any meeting is held to make a
substantive change to the enforcement program.
15
Revision No. Revision Date Summary of Changes
1 10/15/2013 Original version adopted by City Council on October 15, 2013
2 10/07/2014 Annual update: Removed Lewiston and added Colusa
3 6/05/2018 Combined Procurement and Enforcement plan. Included SB350 updates,
removed Colusa biomass project, added cost limitation from stranded
assets, and rearranged information for a clearer, concise document.
4 8/26/2019 Updated to include new legislation on: SB100, and SB1110.
5 4/20/2021 Updated to include new RPS regulatory language from updated regulations
adopted by CEC in December 2020.
6 3/31/2023 Updated optional compliance measure language and corrected
J:\14_RESOURCES\01_PROCEDURES AND FILINGS\PROCEDURES\RPS-001 RPS PROCUREMENT AND ENFORCEMENT PLAN
1
[CL1] Procedure No:
RPS-001
Version:
56
Approval Date:
4/20/20213/21
/2023 RPS Policies &
Procedures Effective Date: April 20, 2021March 21, 2023
Document Owner: Nathan AronsonLisa Casner
REDDING ELECTRIC UTILITY
Resources Division
RPS-001 Renewables Portfolio
Standard Enforcement Program and
Procurement Plan
Reviewed By:
Nathan AronsonLisa Casner (Electric Manager – Resources), Dan
BeansNicholas Zettel (Electric Utility Director)
2
Adopted By: Redding City Council
Date: April 20, 2021March 21, 2023
3
TABLE OF CONTENTS
1. Introduction ......................................................................................................... 43
2. RPS Procurement Plan .......................................................................................... 43
2.1 Purpose ................................................................................................................ 43
2.2 Compliance Periods ............................................................................................. 54
2.3 Portfolio Content Categories (RPS Enforcement Regulation § 3203) ................. 76
2.4 Procurement Requirements (RPS Enforcement Regulation § 3204) ................ 109
2.5 Redding’s Plan for RPS Compliance ................................................................. 1211
3. RPS Enforcement Program ................................................................................ 1211
3.1 Enforcement Policy .......................................................................................... 1211
3.2 Optional Compliance Measures ...................................................................... 1312
4. Review and Updating Requirements ................................................................ 1513
4
1. Introduction
Senate Bill 2 in the First Extraordinary Session (SBX1-2)1 defines the California Renewables
Portfolio Standard (RPS) and imposes minimum renewable energy procurement targets for
all retail sellers and publicly-owned utilities (POUs), including the City of Redding (Redding).
SBX1-2 authorized the California Energy Commission (CEC) to develop procedures for
enforcement of the RPS for POUs. As part of that e nforcement authority, the CEC adopted
“Enforcement Procedures for the Renewables Portfolio Standard for Local, Publicly-Owned
Electric Utilities” (RPS Enforcement Regulations) 2 and updated regulations were
subsequently adopted in 2021. This document describes Redding’s RPS Procurement and
Enforcement Plan, as required by the Public Utility Code (PUC) section 399.30(a), which must
be approved by the Redding City Council.
1.1 Utility Code
Redding maintains compliance with a multitude of state laws that govern certain aspects of
utility energy portfolio requirements. These include the following code sections, which
relate to California’s Renewable Portfolio Standard:
• Renewable Portfolio Standard requirement PUC § 399.30(a)
• Compliance Period and Procurement Targets PUC § 399.30(b) and (c)
• Portfolio Content Categories PUC § 399.16(b) and (c)
• RPS POU Compliance PUC § 399.30(n)
• Optional Compliance Measures PUC § 399.30(d) and PUC § 399.33
2. RPS Procurement Plan
2.1 Purpose
The purpose of the RPS Procurement Plan is to identify the policies and procedures for
Redding to meet the RPS requirements and any future adopted state-defined renewable
goals. SB350 was signed by Governor Brown in 2015, mandating that 50 percent (50%) of
retail sales must be served by RPS eligible resources by 2030. SB350 also mandated Redding
to produce an Integrated Resource Plan that will guide the Procurement Plan as allowed by
PUC section 399.17(d). In 2018, SB100 was signed by Governor Brown, which increased the
RPS goals to 60% by 2030, and in 2021, the CEC approved updates to the RPS regulations.
1 SBX1-2 (Simitian, Stats. 2011, Ch. 1) was signed by California’s Governor on April 12, 2011.
2 The CEC adopted the RPS Enforcement Regulations on June 12, 2013, in Order No. 13 -0612-5.
5
2.2 Compliance Periods
Compliance periods are defined by multi-year percentage targets mandated by law.
Compliance Periods 1, 2, and 3 have passed; however, they are included below for reference:
A. Compliance Period 1
(1) During Compliance Period 1, January 1, 2011, to December 31, 2013, Redding
shall procure, at a minimum, renewable energy resources equivalent to an
average of 20 percent of retail sales over the three (3) years of the compliance
period.
Expressed as:
EP2011 + EP2012 + EP2013 ≥ .20 (RS2011 + RS2012 + RS2013)
Where:
RSX = total retail sales made by Redding for the specified year X.
EPX = electricity products procured for the specified year X; this may include
excess procurement and historic carryover that the POU has chosen to apply
to the compliance period containing year X.
B. Compliance Period 2
(1) For Compliance Period 2, January 1, 2014, to December 31, 2016, Redding shall
procure renewable energy resources to meet or exceed the sum of 20 percent
of retail sales for each of 2014 and 2015, and 25 percent of retail sales for
2016.
Expressed as:
EP2014 + EP2015 + EP2016 ≥ 0.20 (RS2014) + 0.20 (RS2015) + 0.25 (RS2016)
C. Compliance Period 3
(1) For Compliance Period 3, January 1, 2017, to December 31, 2020, Redding shall
procure renewable energy resources to meet or exceed 33 percent of retail
sales by 2020. During the intervening years of Compliance Period 3, Redding
shall increase procurement to reflect an imputed compliance obligati on.
Expressed as:
(EP2017 + EP2018 + EP2019 + EP2020)
≥ 0.27 (RS2017) + 0.29 (RS2018) + 0.31 (RS2019) + 0.33 (RS2020)
6
D. Compliance Period 4
(1) For the compliance period beginning January 1, 2021, and ending December
31, 2024, Redding shall demonstrate it has procured electricity products
within that period sufficient to meet or exceed the sum of 35.75 percent of its
2021 retail sales, 38.50 percent of its 2022 retail sales, 41.25 percent of its
2023 retail sales, and 44.00 percent of its 2024 retail sales.
Expressed as:
(EP2021 + EP2022 + EP2023 + EP2024)
≥ 0.3575 (RS2021) + 0.3850 (RS2022) + 0.4125 (RS2023) + 0.4400 (RS2024)
Redding may not apply Portfolio Content Category 3 RECs in excess of the
maximum limit calculated in section 3204 (c)(3)(A) toward its RPS
procurement target for this period.
E. Compliance Period 5
(1) For the compliance period beginning January 1, 2025, and ending December
31, 2027, Redding shall demonstrate it has procured electricity products
within that period sufficient to meet or exceed the sum of 46.00 percent of its
2025 retail sales, 50.00 percent of its 2026 retail sales, and 52.00 percent of its
2027 retail sales.
Expressed as:
EP2025 + EP2026 + EP2027
≥ 0.4600(RS2025) + 0.5000(RS2026) + 0.5200(RS2027)
Redding may not apply Portfolio Content Category 3 RECs in excess of the
maximum limit calculated in section 3204 (c)(3)(A) toward its RPS
procurement target for this period.
F. Compliance Period 6
(1) For the compliance period beginning January 1, 2028, an d ending December
31, 2030, Redding shall demonstrate it has procured electricity products
within that period sufficient to meet or exceed the sum of 54.67 percent of its
2028 retail sales, 57.33 percent of its 2029 retail sales, and 60.00 percent of its
2030 retail sales.
Expressed as:
EP2028 + EP2029 + EP2030
≥ 0.5467(RS2028) + 0.5733(RS2029) + 0.6000(RS2030)
7
Redding may not apply Portfolio Content Category 3 RECs in excess of the
maximum limit calculated in section 3204 (c)(3)(A) toward its RPS
procurement target for this period.
G. Compliance Periods Beginning on and after January 1, 2031
(1) Compliance periods beginning on and after January 1, 2031, shall be three
years in length starting on January 1 and ending on December 31. For each
compliance period beginning on or after January 1, 2031, Redding shall
demonstrate it has procured electricity products within the compliance period
sufficient to meet or exceed an average of 60.00 percent of Redding’s retail
sales over the three calendar years of the compliance period.
Expressed as:
EPX1 + EPX2 + EPX3 ≥ 0.6000 (RSX1) + 0.6000 (RSX2) + 0.6000 (RSX3)
Redding may not apply Portfolio Content Category 3 RECs in excess of the
maximum limit calculated in section 3204 (c)(3)(A) toward its RPS
procurement target for this period.
2.3 Portfolio Content Categories (RPS Enforcement Regulation § 3203)
In addition to meeting the renewable energy procurement target, the RPS established
Portfolio Content Categories (PCC) that outline the eligible renewable energy resource
products that must be procured to ensure compliance with minimum and maximum values
as summarized in Table 2.
A. PCC1: (RPS Enforcement Regulations § 3203(a))
(1) PCC1 electricity products must be bundled at the time of procurement to be
classified as PCC1, and the POU may not resell the underlying electricity from the
electricity product back to the eligible renewable energy resource from which the
electricity product was procured. The electricity products must be generated by
an eligible renewable energy resource that is interconnected to a transmission
network within the Western Electricity Coordinating Council (WECC) service
territory. For purposes of this section 3203, the first point of interconnection to
the WECC transmission grid is the substation, or, where generation tie lines
interconnect from the eligible renewable energy resource to the network
transmission grid.
(a) Electricity products must be generated by an eligible renewable energy
resource that has its first point of interconnection within the metered
boundaries of a California balancing authority area, or
8
(b) Electricity products must be generated by an eligible renewable energy
resource that has its first point of interconnection to an electricity distribution
system used to serve end-users within the metered boundaries of a California
balancing authority area. For purposes of this section 3203, the first point of
interconnection to an electricity distribution system is within the service area
boundaries of a utility distribution company.
(c) Electricity products from the eligible renewable energy resource with a first
point of interconnection outside the metered boundaries of a California
balancing authority area must be scheduled into a California balancing
authority area without substituting electricity from another source. For
purposes of this section 3203, electricity generated by the eligible renewable
energy resource must be scheduled into a Californ ia balancing authority area
on an hourly or sub-hourly basis. The POU’s governing board, or other
authority as delegated by the POU governing board, must have approved an
agreement before the electricity is generated to schedule the electricity from
the eligible renewable energy resource into the California balancing authority
area on an hourly or sub-hourly basis. If there is a difference between the
amount of electricity generated within an hour and the amount of electricity
scheduled into a California balancing authority area within that same hour,
only the lesser of the two amounts shall be classified as PCC1.
(d) Electricity products must be subject to an agreement between a California
balancing authority area and the balancing authority in which the eligible
renewable energy resource is located and executed before the product is
generated to dynamically transfer electricity from the eligible renewable
energy resource into the California balancing authority area.
(3) Electricity products originally qualifying in PCC1 that do not meet the criteria of
section 3203 (a)(2)(A) and are resold – (D) shall not be counted in PCC1.
B. PCC2: (RPS Enforcement Regulations § 3203(b))
(1) PCC2 electricity products must be generated by an eligible renewable energy
resource that is interconnected to a transmission network within the WECC
service territory, and the electricity must be matched with incremental electricity
that is scheduled into a California balancing authority area.
(2) PCC2 electricity products must be bundled when procured and must meet all of
the following criteria:
(a) The first point of interconnection to the WECC transmission grid for both the
eligible renewable energy resource and the resource providing the
9
incremental electricity must be located outside the metered boundaries of a
California balancing authority area.
(b) The incremental electricity used to match the electricity from the eligible
renewable energy resource must be incremental to the POU. For purposes of
this section 3203, “incremental electricity” means electricity that is
generated by a resource located outside the metered boundaries of a
California balancing authority area; prior to the date of contract or
ownership agreement, electricity is not in the portfolio of the POU claiming
the electricity products for RPS compliance from eligible renewable energy
resources with which the incremental electricity is being matched; is
executed by the POU, or other authority, as delegated by the POU governing
board.
(c) The governing board, or other authority as delegated by the governing board,
executes the contract or ownership agreement for the incremental electricity
at the same time or after the contract or ownership agreement for the
electricity products from the eligible renewable energy resource is executed.
(d) The incremental electricity must be scheduled into the California balancing
authority area within the same calendar year as the electricity from the eligible
renewable energy resource is generated.
(e) The electricity from the eligible renewable energy resource must be available
to be procured by the POU and may not be sold back to that resource.
C. PCC3: (RPS Enforcement Regulations § 3203(c))
All unbundled renewable energy credits and other electricity products procured from
eligible renewable energy resources located within the WECC transmission grid that
do not meet the requirements of either PCC1 or PCC2 fall within PCC3.
D. PCC0: (RPS Enforcement Regulations § 3202(a)(2))
(1) Any contract or ownership agreement originally executed prior to June 1, 2010,
shall count in full toward the procurement requirements if all of the following
conditions are met:
(a) The renewable energy resource met the Commission’s RPS eligibility
requirements that were in effect when the original procurement or ownership
agreement was executed.
10
(b) Any contract amendments or modifications occurring after June 1, 2010, do
not increase the nameplate capacity, expected quantities of annual
generation, or substitute a different renewable energy resource.
(c) If contract amendments or modifications after June 1, 2010, increase
nameplate capacity or expected quantities of annual generation, increase the
term of the contract, or substitute a different eligible renewable energy
resource, only the MWhs or resources procured prior to June 1, 2010, shall
count in full toward the RPS procurement targets. The remaining procurement
that is additional due to the amendment must be classified into a portfolio
content category and as long-term or short-term, and follow the portfolio
balance requirements and long-term procurement requirement in accordance
with RPS Enforcement Regulations section 3204 (c) and 3204 (d).
(d) The duration of the contract may be extended if the original contract specified
a procurement commitment of fifteen (15) years or more.
2.4 Procurement Requirements (RPS Enforcement Regulation § 3204)
A. RPS procurement targets for each compliance period
A POU shall demonstrate it has procured electricity products sufficient to meet or
exceed the procurement requirements for the respective compliance periods listed
below:
Table 1: RPS Renewable Requirement
To allow for market and load variations, Redding may procure additional RECs in each
Compliance Period above the values listed in Table 1.
Compliance Period 4 CP 5 CP 6 CP 7
… 2021 2022 2023 2024 …2027 …2030 2031…
… 35.75% 38.5% 41.25% 44% 52% 60% 60%
Table 1: RPS Renewable Requirement
Compliance Period 4 CP 5 CP 6 CP 7
… 2021 2022 2023 2024 …2027 …2030 2031…
… 35.75% 38.5% 41.25% 44% 52% 60% 60%
11
B. Exemptions and Adjustments
1. Adjustment for Large Hydroelectric Generation
Consistent with RPS Enforcement Regulations § 3204(b)(8), from January 1, 2019,
through December 31, 2030, if Redding receives more than 40 percent (40%) of its
retail sales from large hydroelectric generation during a given year of a compliance
period, Redding is not required to procure electricity p roducts that exceed the lesser
of the portion of the POU’s retail sales unsatisfied by the POU’s large hydroelectric
generation, or the soft target for the relevant year of the compliance period.
2. Adjustment for Qualifying Gas-Fired Power Plant
If all requirements in RPS Enforcement § 3204(b)(11) are satisfied, Redding may
reduce the amount of eligible renewable energy resources that it procures for a
compliance period beginning January 1, 2025, if the gas-fired power plant is operating
at or below a 20 percent (20%) capacity factor on an annual average basis during a
given compliance period. This amount is calculated by the difference between the gas-
fired power plant’s actual generation for the compliance period if it had operated at
a 20 percent (20%) capacity factor on an annual average during the compliance
period. In order to participate, Redding was required to notify the CEC of its intent to
act pursuant to this exemption by April 1, 2019. Redding submitted its notification to
the CEC on March 12, 2019, and it was accepted by the CEC on July 31, 2019.
C. Portfolio Balance Requirements
Beginning January 1, 2021, within Compliance Period 4, at least sixtyseventy-five
percent (765%) of Redding’s RPS procurement for each compliance period shall be
from PCC 1 contracts, with a maximum of 10 percent of Redding’s RPS procurement
from PCC 3 RECs of 10 years or more in duration or ownership or ownership
agreements for eligible renewable energy resources (PUC section 399.136(b) and
399.30(d)). There is no direct restriction on the percentage of PCC 2.[CL2]
REC
Classification
Compliance
Period 1
2011-2013
Compliance
Period 2
2014-2016
Compliance
Period 3
2017-2020
Compliance
Period 4
2021-2024
Compliance
Period 5
2025-2027
Compliance
Period 6
2027-2030
PCC1 RECs
(Minimum) 50% 65% 75% 75% 75% 75%
PCC2 RECs
(No Direct
Restriction)
n/a n/a n/a n/a n/a n/a
PCC3 RECs
(Maximum) 25% 15% 10% 10% 10% 10%
PCC0 Not subject to portfolio balancing requirements
Table 2: RPS Balancing Requirement
12
D. Long-Term Portfolio Requirement
For the compliance period beginning January 1, 2021, and each compliance period
thereafter, at least 65 percent of the electricity products applied toward the RPS
procurement target shall be from contracts of 10 years or more in duration or
ownership or ownership agreements for eligible renewable energy resources (PUC
section 399.13(b) and 399.30(d)). long-term procurement.
Electricity products will be classified as long-term or short-term based on the
contracts, ownership, or ownership agreements through which they are procured.
For the purpose of this section 3204 (d) subdivision, long-term procurement refers
to procurement from long-term contracts (over ten years in duration), ownership, or
ownership agreements, subject to criteria outlined in section 3204 (d).
2.5 Redding’s Plan for RPS Compliance
In order to meet the RPS mandates, Redding plans to preserve its existing PCC0 resources,
carry forward excess procurement from one compliance period to the next, and look for
valuable opportunities to diversify and expand its RPS portfolio while protecting Redding’s
customers from excessive rate increases that could jeopardize economic growth and viability
within the City.
The Integrated Resource Plan (IRP) will be the guiding document and framework used for
future RPS energy procurement efforts. The IRP will be used as a procurement guide for RPS
resource quantity, timing, location, and generation profiles. The IRP is filed with the
California Energy Commission and will follow the required timely updates.
Redding plans to continue evaluating eligible renewable power resources and will initiate any
necessary procurement solicitations consistent with the IRP approved by the California
Energy Commission.
3. RPS Enforcement Program
3.1 3.1 Enforcement Policy
In compliance with the requirement for the governing board of a POU to adopt a program for
enforcement of the legislation prior to January 1, 2012, the Redding City Council passed
Resolution 2011-197 “Resolution of the City Council of the City of Redding to Revise the
Renewable Portfolio Standard for the City of Redding’s Electric System” on December 20, 2011.
Resolution 2011-197 adopted the following RPS targets:
13
• An average of 20 percent in 2011 through 2013;
• 25 percent by 2016; and
• 33 percent by 2020 and thereafter.
Resolution 2011-197 also adopted the following Enforcement Policies:
• Redding will make a reasonable effort in the context of Good Utility Practice to be in
compliance with the requirements of SBX1-2.
• Redding will report to the City Council on its status of compliance with SBX1-2 per PUC
section 399.13.
• Redding will notify the City Council of any potential for lack of compliance with the
requirements that may be considered for a notice of violation and penalty imposition.
• Redding will provide an explanation and analysis to the City Council on such potential
for lack of compliance, as well as a plan of corrective action and timeframe for
returning the City to compliant status.
The Redding City Council approved updated RPS goals on September 17, 2019 , due to the
passing of SB 100, which accelerated RPS goals previously established in SB 350 as follows:
• 44 percent by 2024;
• 52 percent by 2027;
• 60 percent by 2030 and thereafter.
The Redding City Council approved the updated RPS goalsprocurement plan on xxMarch 21/xx,
/2023, modifying how Redding utilizes the plan’s Optional Compliance Measures.
3.2 Optional Compliance Measures
Specific optional compliance measures are permitted and are adopted by Redding and the
City Council. Redding adopts the following optional compliance measures, which may be
utilized in the event that factors beyond reasonable control interfere with its ability to meet
the procurement requirements set forth in § 3206 of the RPS Regulations.
A. Excess Procurement:
14
Redding shall be allowed to apply Excess Procurement from one compliance period to
subsequent compliance periods using the criteria outlined in § 3206(a)(1) of the RPS
Enforcement Regulations.
B. Delay of Timely Compliance:
Enforcement of timely compliance shall be waived if Redding demonstrates that any
of the conditions defined in RPS Enforcement Regulations § 3206(a)(2) are beyond the
control of Redding, and Redding would have met its RPS procurement requirements
but for the cause of delay.
C. Cost Limitations for Expenditures:
The City of Redding’s current RPS policy requires that Redding pursue target levels of
renewable purchases while ensuring that costs for renewable purchases do not result
in disproportionate rate impacts to customers. To ensure customers do not face a
disproportionate burden, Redding’s City Council has the authority to implement a cost
limitation, which may result in the temporary suspension of RPS compliance activities.
In this section, Redding establishes a Cost Limitation on the procurement
expenditures for all eligible renewable energy resources used to comply with the RPS,
consistent with RPS Enforcement Regulations § 3206(a)(3). Potential reliance on this
provision for compliance will be consistent with the City’s renewable energy
procurement plan and the schedule that satisfies the procurement requirements set
forth in Section 2.4 of this document.
In applying the The Cost Limitation provision to each RPS procurement expenditure,
Redding applied to each RPS procurement expenditure will consider the following:
(1) Incorporating the annual RPS expenditure into Redding’s current portfolio
should not require rate increases of more than 1.5 percent per year at any time
during the life of the considered RPS procurement.
Redding wilshall develop an RPSa renewable energy procurement plan and schedule that
satisfies the procurement requirements set forth in Section 2.4 herein. Procurement
requirements in excess of this schedule that are not related to a change in electric retail sales
will be considered an undue burden on customers.
R
(1) Renewable energy procurement requirements exceeding this schedule that are
not related to a change in electric retail sales will be considered a deviation from
the forecast.
15
(2) The projected cCosts incurred to meet renewable energy procurement
mandates for the given compliance period causing that are above and beyond
what is expected and included in the adopted budget any increase from the
adopted budget shall be considered a disproportionate burden to customers.
(2) The per-kilowatt-hour cost of the considered RPS procurement expenditure
should not exceed, nor be projected to exceed, 75 percent of Redding’s current per-
kilowatt-hour retail residential energy charge.
(3) When estimating the considered RPS procurement expenditure, the following
costs will also be included:
(a) The costs associated with the energy, renewable attribute, firming and
shaping, and/or storage, as needed for intermittent resources; and
(b) The costs associated with delivery of thethe delivery of renewable
energy.
In the event that renewable energy procurement expenditures exceedrequirements
meet the threshold for utilization of the adoptedthe Cost Limitation Optional
Compliance Measure, Redding shall re-evaluatereview its RPS Procurement Plan to
ensure that other options are not available that would otherwise allow Redding to
meet its RPS procurement requirement. Such review will include an re-evaluation of
current procurement commitments, planned procurements, long-term
commitments, and the availability of alternative resources in other portfolio content
categories. Based on this review, Redding reserves the right to refrain from entering
into new contracts for renewable energy purchases or products that exceed the
quantity limited threshold required in its listedthe Ccost Llimitation provisions. ….
D. Portfolio Balance Requirement Reduction:
The Portfolio Balance Requirement shall be reduced if Redding demonstrates that any
of the conditions defined in RPS Enforcement Regulations § 3206(a)(4) are beyond the
control of Redding, and Redding would have met its Portfolio Balance Requirements
but for the cause of reduction.
4. Review and Updating Requirements (RPS Enforcement Regulations § 3205(a)
and (b))
Redding is required to complete an Integrated Resource Plan that will guide the Procurement
plan. Redding will provide the following notice regarding new or updated renewable energy
resources procurement and enforcement plans:
16
A. Renewable Energy Resources Procurement Plan
(1) Redding shall post notice in accordance with Chapter 9 (commencing with § 54950)
of Part 1, Division 2, Title 5 of the Government Code, whenever the City Council will
deliberate in public on the RPS Procurement Plan.
B. Enforcement Plan
(1) Redding shall provide notice regarding new or updated enforcement programs. The
enforcement program must be adopted at a publicly noticed meeting offering all
interested parties an opportunity to comment.
a. No less than 30 calendar days’ notice shall be given to the public of any
meeting held for purposes of adopting the enforcement program.
b. If the enforcement program is modified or amended, no less than 10 calendar
days’ notice shall be given to the public before any meeting is held to make a
substantive change to the enforcement program.
Revision No. Revision Date Summary of Changes
1 10/15/2013 Original version adopted by City Council on October 15, 2013
2 10/07/2014 Annual update: Removed Lewiston and added Colusa
3 6/05/2018 Combined Procurement and Enforcement plan. Included SB350 updates,
removed Colusa biomass project, added cost limitation from stranded
assets, and rearranged information for a clearer, concise document.
4 8/26/2019 Updated to include new legislation on: SB100, and SB1110.
5 4/20/2021 Updated to include new RPS regulatory language from updated regulations
adopted by CEC in December 2020.
6 3/31/2023 Updated optional compliance measure language and corrected
J:\14_RESOURCES\01_PROCEDURES AND FILINGS\PROCEDURES\RPS-001 RPS PROCUREMENT AND ENFORCEMENT PLAN