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RPS Compliance and Enforcement Presentation to the: FPSC Staff Workshop on a Renewable Portfolio Standard September 27, PowerPoint Presentation
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RPS Compliance and Enforcement Presentation to the: FPSC Staff Workshop on a Renewable Portfolio Standard September 27, 2007 Judy Harlow Division of Economic Regulation Florida Public Service Commission. RPS Compliance. Verification methodologies: 1) Contract path

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Presentation Transcript
slide1

RPS Compliance and Enforcement

Presentation to the:

FPSC Staff Workshop

on a Renewable Portfolio Standard

September 27, 2007

Judy Harlow

Division of Economic Regulation

Florida Public Service Commission

rps compliance
RPS Compliance

Verification methodologies:

1) Contract path

2) Renewable Energy Credits (RECs)

3) Utility ownership of renewable facility

Once a verification methodology is chosen, how do we make it work?

slide3

RPS Compliance

  • Common Issues:
  • Who administers verification of compliance?
  • - state agency or third party
  • Should there be a weighting system based on objectives?
  • - multipliers or tiered approach
  • Should there be a safety valve, such as an alternative compliance payment?
    • - who administers
    • - use of funds
    • - recovery for IOUs
  • Should self-service generation be counted toward goals?
slide4

RPS Compliance

  • Issues that are specific to RECs:
    • Should out-of-state RECs be counted?
    • - regional limitation
    • - requirement that energy be delivered to Florida
    • - coordination to prevent double counting
    • What flexibility measures should be allowed?
    • - banking
    • - borrowing
    • - true-up period
slide5

RPS Enforcement

How often should utilities be reviewed?

- annual or other interim goals

What is the best way to ensure compliance?

- penalties versus guidelines

Penalty-specific issues:

- How should penalties be applied?

- How should funds be used?

- Who administers the funds?

- Force majeure exceptions?

- Should IOUs receive recovery?

slide6

RPS Enforcement

Should we establish a baseline of current renewables?

- If so, what counts toward baseline?

What reporting requirements are needed?

Should there be a process to review the RPS?

- automatic process such as conservation goals proceedings (review every 5 years)

- ongoing review with no automatic process