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CPUC staff proposes Clean Energy Standard option to align procurement with IRP greenhouse‑gas targets
Summary
Staff proposed a Clean Energy Standard (CES) modeled after RPS compliance, using a percentage‑of‑sales target derived from IRP modeling to close the gap between existing programs and electric‑sector GHG targets. The proposal would use REC‑style instruments (tracked in the registry) and a $50/MWh penalty for multi‑year compliance shortfalls.
CPUC staff proposed a Clean Energy Standard (CES) as the greenhouse‑gas procurement component of the RCPP staff proposal. The CES is modeled on the existing RPS structure and would set annual targets (percentage of retail sales) that LSEs must meet over multi‑year compliance periods.
“The CS option would build on the proven success of the renewable portfolio standards program,” said Sierra Withers, a Utilities Engineer on IRP staff who presented the GHG portion of the proposal.
Staff said the CES percentage would be derived from Resolve modeling run with binding electric‑sector greenhouse‑gas targets and then allocated to LSEs proportionally by retail sales. Staff emphasized the approach is intended to be scalable, use standardized, trackable compliance instruments and avoid overlap with California Air Resources Board (CARB) mass‑based regulation.
Staff proposed that compliance be measured on multi‑year compliance periods aligned to the RPS schedule (three‑year compliance periods). Staff proposed that compliance be enforced on a backward‑looking basis at the end of each compliance period, with penalties set at $50 per megawatt‑hour for each megawatt‑hour of deficiency. Staff also proposed leveraging the existing REC registry and verification processes to track eligible clean energy generation and any new ‘‘zero‑emission’’ instrument definitions needed to implement the CES.
Staff framed the CES as a mechanism to close the gap between existing policy constraints and the higher GHG reductions modeled in Resolve. Sierra Withers said the CES is intended “to send signals for procurement of additional clean energy beyond requirements in order to achieve California’s greenhouse‑gas reduction goals.”
Staff asked parties whether other mechanisms could achieve the same result, and invited detailed comment on instrument design, eligibility rules, and how to coordinate CES accounting with RPS and with CARB programs.
Questions from stakeholders at the workshop ranged from instrument definitions (how to treat non‑RPS zero‑carbon resources) to timing and the administrative burden of registering and verifying new credit instruments. Staff asked parties to file written comments by July 15 and suggested additional stakeholder engagement to resolve detailed implementation questions.
