By: Adam Gerza, 10/27/11

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The California Energy Commission (CEC) held their long anticipated Staff Workshop to discuss proposed changes to the Renewables Portfolio Standard (RPS) Eligibility Guidebook on Friday, October 21st (it was delayed from October 7th).  The 3 hour audio recording and presentation slides are available on the CEC website.

This blog attempts to summarize the key points, which pertain to in-state Renewable Energy Credits (RECs).  It is important to note that at this stage these are still proposed changes, and the Guidebook revisions have not yet been finalized or approved.

Unbundled Renewable Energy Credits were discussed at several points during the staff presentation, and also during the public comments section of the workshop.  Three specific requirements for in-state facilities to get CEC certification were laid out: (1) participation in WREGIS, (2) meter accuracy rating of 2 percent or higher, (3) only generation occurring after the certification’s “beginning on date” would be considered eligible.

The “beginning on date” is defined as the date the CEC receives the certification application, assuming that the generator facility goes on to get approved.  This is a shift from the way prior language had been suggesting.  Previously it was understood that RECs banked in WREGIS would already be RPS eligible and have a 3-year tradable life.  If this particular guidebook revision is adopted, RECs previously banked in WREGIS would not yet be RPS eligible.  The earliest “beginning on date” for CEC certification would likely be in December 2011 or January 2012.

Also mentioned several times throughout the staff presentation was SB X1-2, the California RPS bill that was signed into law in April of this year.  The CEC is aware of the rulemaking currently underway at the California Public Utilities Commission (CPUC), and is acknowledging that they may need to further amend the RPS Eligibility Guidebook based on any SB X1-2 revisions.  The focal point issue that we have discussed in a previous blog is what “bucket” in-state generators of unbundled RECs will be classified into.

It was mentioned briefly by a staff presenter that currently the CEC has certified somewhere around 1,700 facilities as being RPS eligible.  And they estimate that once the Guidebook changes get adopted, between 50,000 to 80,000 generators will become eligible and may look to apply for RPS certification.  It is encouraging to hear that the CEC recognizes the upcoming scale issue, and hopefully designs their application and certification process accordingly.

The CEC is planning to adopt the Guidebook by no later than January of 2012.  Leaf Exchange will be submitting formal comments to the CEC in order to protect the best interest of our customers on a number of issues.  We post our comments to the Policy & Legislation page on our website.