Senate Bill 881 – Load Serving Entities: Integrated Resource Plans (Min)

While we agree that systems must be in place to ensure that the electricity sector continues to reduce greenhouse gas emissions so California can meet its climate goals, the bill as drafted, lacks critical boundaries, and includes vague standards that not only infringe upon CCA procurement autonomy but would lead to increased costs to ratepayers.

We shared with the author and sponsors, that there are three major areas of concern for CCAs:

1. The bill does not specify a certain, actionable LSE-specific GHG reduction standard. Today there is no LSE-specific standard set by statute or by the Air Resources Board (ARB); achievement of the GHG reduction goals is monitored in the Integrated Resource Plan (IRP) with standards – sometimes multiple – changing in each IRP cycle. Certainty and clarity in the standard, as the Renewable Portfolio Standard (RPS) imparts, are critical to LSEs obligated to meet the standard.
2. The bill places the ill-defined standard in the context of a relatively new, evolving process that does not provide a stable ground for a new compliance structure. Enforcing plans proposed in the IRP proceeding would be counterproductive; while the IRP examines the ability to achieve the standards it establishes from time to time; LSEs must have flexibility to modify their plans as market conditions and customer needs evolve.
3. The bill will add a significant administrative burden and thus increase customer costs.

CalChoice is meeting with the author and expressing our concerns on SB 881.