HomeMy WebLinkAboutRESO 9913
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Resolution No. 9913
Resolution of the Council of the City of Palo Alto Amending the
Electric Supply Portfolio Carbon Neutral Plan and the Electric
Utility Reserves Management Practices
R E C I T A L S
A. The City of Palo Alto (the “City") provides electricity to residential and commercial
customers located within its jurisdictional boundary.
B. In an effort to combat climate change, in December 2007 the City adopted the
Climate Protection Plan, which set aggressive greenhouse gas (“GHG”) emission reduction goals
to be achieved by the year 2020.
C. Further to its GHG emissions reduction goals, in November 2016 the City
adopted a Sustainability and Climate Action Plan (“S/CAP”), and in December 2017 the City
adopted a 2018-2020 Sustainability Implementation Plan (“SIP”).
D. In order to achieve these aggressive GHG emissions reduction goals, in March
2013, through Resolution No. 9322, the City adopted a Carbon Neutral Plan for the electric supply
portfolio, with a goal of achieving carbon neutrality by 2013.
E. In the 2013 Carbon Neutral Plan, the City defined carbon neutrality based on an
annual accounting of the City’s load and its carbon neutral electric resources: an electric supply
portfolio that “will demonstrate annual net zero greenhouse gas (GHG) emissions, measured at
the Citygate, in accordance with The Climate Registry’s Electric Power Sector protocol for GHG
emissions measurement and reporting.” At the time this definition of carbon neutrality was
adopted, this was the most granular accounting approach feasible (given the lack of hourly grid
emissions data) or necessary (given the small amount of solar capacity installed at that point, and
the resulting emissions profile of grid electricity).
F. Based on this definition of carbon neutrality, the City has achieved its Carbon
Neutral Plan objectives each year starting in 2013, primarily through its long-term contracts for
in-state hydroelectric and Renewable Portfolio Standard (“RPS”) eligible resources, with some
reliance on RPS-eligible unbundled renewable energy certificates (“RECs”) for 2013-2015.
G. Due to limitations on the use of unbundled RECs (“Bucket 3 RECs”) for compliance
with the state’s RPS mandate (only 10% of a utility’s RPS procurement may consist of Bucket 3
RECs), a significant financial premium currently exists for in-state bundled renewable energy
resources (“Bucket 1 RECs”).
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H. As a result of its pursuit of its Carbon Neutral Plan objectives, the City’s electric
supply portfolio currently far exceeds the procurement requirements of the state’s RPS mandate,
and all of the City’s current RPS resources are classified as Bucket 1 RECs.
I. Due to the impacts of the county and state stay-at-home orders put in place since
March 2020, in response to the COVID-19 pandemic, the City’s electric utility retail sales volumes
(and revenues) have declined approximately 10% from baseline levels, which has put a strain on
the City’s electric utility financial reserves.
J. Through Resolution 9487, adopted in January 2015, the City established a policy
on the use of revenue from the sale of allowances freely allocated to the City’s electric utility
under the state’s Cap and Trade Program (“Cap and Trade Revenue Use Policy”). This policy
authorizes the City Manager or their designee to use these allowances and allocate the resulting
revenue to certain approved types projects or expenditures, in compliance with CARB
regulations.
K. Consistent with the City’s Cap and Trade Revenue Use Policy, for Fiscal Years 2021
and 2022, an amount equivalent to at least one-third of the revenues earned from the REC
Exchanges would be allocated from the City’s Cap and Trade Reserve to local decarbonization
efforts; thereafter the City would prioritize local decarbonization efforts with these funds.
The Council of the City of Palo Alto does hereby RESOLVE, as follows:
SECTION 1. The Council approves the updated Electric Supply Portfolio Carbon Neutral
Plan (attached, with changes shown in redline, as Exhibit A), which modifies the definition of
carbon neutrality to use an hourly carbon emissions accounting standard; authorizes the
exchange of bundled RECs from the City’s long-term renewable resources (Bucket 1 RECs) for
RPS-eligible, unbundled RECs (Bucket 3 RECs), to the maximum extent possible, while maintaining
compliance with the state’s RPS regulations in order to minimize electric supply portfolio costs
(“REC Exchanges”); and authorizes the purchase of RPS-eligible, unbundled RECs (Bucket 3 RECs)
as needed to neutralize any residual emissions resulting from the difference between emissions
calculated under an annual accounting and hourly accounting methodology for calendar years
2020 through 2024.
SECTION 2. The Council approves the creation of a Cap and Trade Program Reserve in
the Electric Fund which will hold revenues from the sale of carbon allowances freely allocated to
the electric utility under the State’s Cap and Trade Program.
SECTION 3. The Council directs staff to return to Council in 2022 to review the
authorization to minimize electric supply portfolio costs via REC Exchanges;
SECTION 4. The Council directs staff to return to Council by the end of 2024 with a
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review of the Carbon Neutral Plan to evaluate the effectiveness of these policy changes and to
modify them if necessary (with a particular focus on reviewing the use of Bucket 3 RECs to
neutralize any residual emissions resulting from the switch to an hourly emissions accounting
methodology).
SECTION 5. The Council finds that the adoption of this resolution updating the City’s
Electric Supply Portfolio Carbon Neutral Plan is not subject to California Environmental Quality
Act (CEQA) review because it is an administrative government activity that will not result in any
direct or indirect physical change to the environment (CEQA Guidelines section 15378(b)(5)).
INTRODUCED AND PASSED: August 24, 2020
AYES: CORMACK, DUBOIS, FILSETH, FINE, KNISS, KOU, TANAKA
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
___________________________ ___________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
___________________________ ___________________________
Assistant City Attorney City Manager
___________________________
Director of Utilities
___________________________
Director of Administrative Services
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EXHIBIT A
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Adopted by City Council on March 4, 2013
Revised by City Council on August 24, 2020
City of Palo Alto Utilities
Electric Supply Portfolio Carbon Neutral Plan
1. Carbon Neutral Definition
A carbon neutral electric supply portfolio will demonstrate annual net zero greenhouse gas (GHG)
emissions, measured at the Citygate1, by applying the average hourly carbon emissions intensity
of the electricity on the CAISO grid to the City’s net load for each hour of the year.
2. Carbon Neutral Plan Objective
Reduce the City of Palo Alto’s overall community GHG emissions by achieving carbon neutrality
for the Electric Supply Portfolio starting in calendar year 2013 within an annual rate impact not
to exceed 0.15 cents per kilowatt-hour (₵/kWh) primarily through the: 1) engagement of
customers to increase energy efficiency; 2) expansion of long-term renewable resource
commitments; 3) promotion of local renewable resources; 4) continued reliance on existing
hydroelectric resources; and 5) meeting short-term balancing requirements and/or neutralizing
residual carbon through the use of short-term purchases of renewable resources and/or
renewable energy certificates (RECs).
3. Resource Strategies
a. Energy Efficiency
i. Continue to pursue energy efficiency strategies as identified in the Council-
approved ten-year Energy Efficiency Plan.
b. Long-term Renewable Resources
i. Continue to pursue the City’s Renewable Portfolio Standard (RPS) goal to
purchase renewable energy to supply at least 60% of retail sales by 2030 while
ensuring that the retail rate impact of these purchases does not exceed 0.5
₵/kWh.
ii. Continue to pursue local renewable resources through the Palo Alto CLEAN
program.
iii. Pursue additional long-term renewable resources (beyond the RPS goals) to
achieve a target of 100% carbon-free resources based on average year
hydroelectric generation.
1 Citygate is the location of the City’s main meter where the City interconnects to the Pacific Gas and Electric
transmission system. Emissions associated with of the output of the locally sited fossil gas fired combustions units
(COBUG), while not measured at Citygate, will be neutralized.
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EXHIBIT A
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c. Short-term Renewable Resources and Renewable Energy Certificates
i. Minimize electric supply portfolio costs by exchanging bundled RECs from the
City’s long-term renewable resources (Bucket 1 RECs) for RPS-eligible, unbundled
RECs (Bucket 3 RECs) to the maximum extent possible while maintaining
compliance with the state’s RPS regulations;
ii. For calendar years 2020 through 2024, procure additional short-term
renewables or RPS-eligible, un-bundled RECs (Bucket 3 RECs) as needed to
achieve carbon neutrality based on actual load and resources;
iii. Neutralize anthropogenic GHG emissions associated with the City’s purchase of
renewable resources with RPS-eligible unbundled-RECs (Bucket 3 RECs).
d. Banking and Truing Up
i. In the event that there are surplus renewables beyond the City’s load in a
particular year, bank RECs from qualifying renewables from that year to
minimize the need for purchasing RECs in subsequent years.
ii. For calendar years 2020 through 2024, neutralize residual emissions that result
from applying an hourly emissions accounting methodology, rather than a net
annual generation methodology, with RPS-eligible unbundled-RECs.
4. Hydroelectric Resources
a. Continue to preserve and advocate for existing carbon-neutral hydroelectric generation
resources that provide approximately 50% of average year resource needs.
b. Plan for and acquire carbon neutral resources assuming average hydroelectric
conditions going forward.
c. Under adverse hydroelectric conditions, procure RPS-eligible unbundled-RECs to achieve
carbon neutrality up to the 0.15 ₵/kWh rate impact limit and seek Council direction if
carbon neutrality cannot be achieved within the rate impact limit.
d. Under favorable hydroelectric conditions, where carbon neutral resources are expected
to be surplus to needs, even after allowable banking, then pursue selling short-term
renewable energy, or the renewable attributes, associated with one or more carbon-
neutral resources in the portfolio.
5. Financial and Rate Payer Impacts
a. In addition to the RPS annual rate impact limit of 0.5 ₵/kWh, the cost of achieving
carbon neutrality shall not exceed 0.15 ₵/kWh.
b. Revenues collected from surplus energy sales related to hydroelectric resources under
favorable conditions (e.g. wet years), will be maintained within reserves to adjust for the
cost of achieving carbon neutrality under adverse hydroelectric years.
c. To the extent available and allowable, revenues from the auction of cap-and-trade
allowances may be used to fund resources acquired to meet the carbon neutrality goals.
6. Reporting and Communication
a. Develop a communication plan for stakeholders to inform them of the City’s efforts
towards achieving a carbon neutral electric supply.
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EXHIBIT A
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b. Provide customers a report of the electric supply portfolio’s carbon content to
supplement the mandated Power Content Label.
c. Inform large commercial and/or corporate customers of the City’s carbon neutral
portfolio and its relevance to their individual corporate sustainability goals.
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Certificate Of Completion
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Subject: Please DocuSign: RESO 9913 Revised Carbon Neutral Plan.docx, RESO 9913 Exhibit A Revised Carbon...
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