RPS Compliance and Enforcement

1
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
2
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?

3
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?
4
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
5
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?
6
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