Amend the state’s RPS (RCW 19.285) to:
- repeal mandates to purchase power that is not required to meet the utility’s load,
- allow incremental power generated as a result of efficiency improvements at federal hydro facilities to count towards a utility’s RPS requirements,
- provide greater renewable energy credit (REC) banking flexibility,
- allow conservation and energy efficiency achievements to count towards the utility’s renewable energy requirements, and
- exempt “small utilities” as defined in RCW 19.29A without any increase in the renewable energy or conservation requirements.
Washington’s economy has been built on an abundant, reliable and affordable electric energy. Clean, reliable, renewable, low-cost hydropower accounts for over 80 percent of the power sold by the typical electric cooperative in Washington. Over 90 percent of the power sold by cooperative utilities does not emit any greenhouse gases.
In 2006, voters narrowly passed Initiative 937 establishing a renewable portfolio standard (RPS) for all utilities serving over 25,000 Washington consumers. I-937 mandates that qualifying utilities obtain 15% of their energy supply in 2020 and beyond from defined “eligible renewable resources”. Existing hydropower is not recognized as an “eligible renewable resource”. I-937 also has a separate mandate requiring covered utilities to acquire all cost-effective, reliable, and feasible conservation.
I-937 does not recognize conservation achievements and other factors impacting a utility’s actual needs for new resources at the I-937 mandated compliance levels (3% by 2012, 9% by 2016, and 15% by 2020). These mandates have the effect of forcing utilities with existing generating resources to acquire unneeded, higher-cost eligible renewable resources or renewable energy credits (RECs) ahead of need rather than when needed. Being forced to acquire power or RECs ahead of need is inconsistent with sound business practices and costs utility consumers tens of millions of dollars. Additionally, the I-937 definition of eligible renewable resources is too narrowly defined and can limit the development of new, low or non-carbon, job producing technologies.
The legislature should consider sensible, cost-effective changes to I-937, including:
- Allow a utility to delay the purchase of the mandated eligible renewable power or RECs until the utility actually needs the power to serve its consumers.
- Expand the definition of eligible renewable resources to promote the development of additional renewable resources such as new generation at existing dams, incremental electricity produced through efficiency improvements at federal hydroelectric generation facilities, low impact hydro, and hydro that is used to integrate eligible renewable resources (i.e. wind power).
- Some utilities have already purchased eligible renewable power and/or RECs based on the existing compliance mandates. Therefore, the period of time in which RECs can be used for compliance should be greatly extended so those utilities are not harmed by a change in the law as noted in 1 and 2 above.
- Recognize that the conservation and the eligible renewable resource mandates must be complimentary and recognize that conservation can reduce the need for new eligible resources.
- Change the definition of “small utility” to match the long-standing definition in RCW 19.29A which defines a “small utility” as having less than 25,000 customers or fewer than seven customers per mile of line.