HomeMy WebLinkAboutStaff Report 104-11
TO: HONORABLE CITY COUNCIL
FROM: CITY MANAGER DEPARTMENT: UTILITIES
DATE: JANUARY 10, 2011 CMR: 104:11
REPORT TYPE: CONSENT
SUBJECT: Utilities Advisory Commission Recommendation to Adopt a
Resolution Approving the City of Palo Alto Utilities’ Legislative
Policy Guidelines for 2011
RECOMMENDATION
Staff and the Utilities’ Advisory Commission (UAC) recommend that the City Council adopt a
resolution approving the Utilities’ Legislative Policy Guidelines for 2011.
EXECUTIVE SUMMARY
The Utilities’ Legislative Policy Guidelines for 2011 (Attachment B) have been developed by
staff and reviewed by the UAC to: 1) provide direction to staff in evaluating and responding to
legislative action involving utilities and utilities issues, and 2) clarify approved policy and
advocacy direction when active involvement of Palo Alto elected officials is required.
The guidelines are grouped in five sections: the first addressing legislative policy guidelines that
are common to all utilities (electric, gas, water, wastewater, and fiber), and the following four
sections addressing those guidelines that are specific to water, gas, electric, or wastewater
collection. Each section includes a set of goals for the utility and guidelines for Palo Alto staff
and elected officials when taking action to achieve the goals.
DISCUSSION
The utility industry is a high profile and heavily regulated industry that is subject to copious
legislative actions at both the regional state and federal level. Such legislation can influence,
among other things, the quality of supplies, reliability and security of the supply and distribution
infrastructure; commodity procurement practices; customer service and billing; program design;
rate design; and activities and costs associated with climate protection. Representatives of the
City (elected and appointed officials and staff) participate in federal and state legislative forums
to advocate positions on energy and water-related issues that support the City Utilities
Department’s key objectives of providing valued utility services to customers while cost
effectively balancing environmental solutions. The City Utilities Department also participates in
joint action efforts to advocate for goals and objectives shared by other public owned utilities.
CMR: 104:11 Page 1 of 3
At the state level, hundreds of bills focused on the utility industry can be introduced each year.
The number of bills introduced, the pace at which bills change and new language is negotiated,
and the often surprising speed at which bills can be placed for a vote during the legislative year
requires Utilities Department staff and elected officials to respond quickly if the City is to have
any influence on the resulting legislation. Often, a response to an amended bill is required in a
matter of days. These timing constraints preclude a return to the UAC and Council for approval
each time a response is required. Therefore, a set of policy guidelines is developed each year
that identifies the goals and priorities for the Utilities Department to be applied by staff when
evaluating and responding to legislation.
While it is impracticable to return for approval each time a letter is sent in response to a bill
amendment, the issues under debate are known to the UAC and Council through their
participation in legislative committee meetings, the publications and summaries circulated from
joint action agencies, and updates from the Utilities Director and her staff. Advocacy positions
taken in alignment with these guidelines will be subject to the approval of the Utilities Director
or City Manager per the City’s legislative advocacy process.
BOARD/COMMISSION REVIEW AND RECOMMENDATIONS
The Utilities’ Legislative Policy Guidelines for 2011 were presented to the UAC at its December
1, 2010 meeting. There was discussion about the new guidelines proposed and the UAC
proposed some changes to make guidelines more generally applicable to legislative remedies.
The UAC unanimously approved a motion to recommend that the City Council approve the
Utilities’ Legislative Policy Guidelines for 2011 with the changes discussed. The motion carried
unanimously (6-0), with Commissioner Keller absent. Draft minutes from the UAC meeting are
included as Attachment C.
Staff has incorporated the changes recommended by the UAC into the attached proposed
Utilities’ Legislative Policy Guidelines for 2011.
RESOURCE IMPACT
There is no direct resource impact associated with adoption of the proposed legislative policy
guidelines. However, actions taken that support the efficient use of the City’s assets and
resources will help control costs, implement the Council’s policies and goals, and protect utility
customers.
POLICY IMPLICATIONS
The recommendation is consistent with the Council policy and supports the Council’s 2010
priorities of City Finances and Environmental Sustainability.
ENVIRONMENTAL REVIEW
Approval of a Resolution Adopting the Utilities’ Legislative Policy Guidelines for 2011 does not
meet the definition of a project pursuant to Section 21065 of the California Environmental
Quality Act (CEQA), thus, no environmental review is required.
CMR: 104:11 Page 2 of 3
ATTACHMENTS
A. Resolution Adopting the Utilities' Legislative Policy Guidelines for 2011
B. Utilities' Legislative Policy Guidelines for 2011
----C ··Excerpt-from-Dra±tUAC-MectingMinutesofDecemberl, 2010
PREPARED BY: DEBRA LLOYD VL
Acting Assistant Director, Resource Management
DEPARTMENT APPROVAL: VAL1r~~r-N-G----------
Director of Utilities
CITY MANAGER APPROVAL:
CMR: 104:11 Page 3 of3
* NOT YET APPROVED*
1
110105 dm 6051482
Resolution No.
Resolution of the Council of the City of Palo Alto
Approving the City of Palo Alto Utilities' Legislative
Policy Guidelines for 2011
WHEREAS, the City of Palo Alto Utilities Strategic Plan (“Strategic Plan”),
approved by the Council of the City of Palo Alto on March 7, 2005, [CMR 148:05] provides a
set of Key Objectives for the City of Palo Alto Utilities Department (CPAU) to follow in the
areas of customer satisfaction and utility infrastructure, employment of balanced environmental
solutions, provision of competitive rates to customers through municipal ownership, and
assurance of a safe and engaged workforce; and
WHEREAS, CPAU annually identifies Utilities’ Legislative Policy Guidelines
that facilitate the Strategic Plan’s Key Objectives; and advocates for utility-related issues at
Federal and State legislative forums in furtherance of those objectives; and
WHEREAS, in November 2010 CPAU staff updated the Legislative Policy
Guidelines to respond to recent legislative and regulatory trends; and
WHEREAS, the 2011 Legislative Policy Guidelines also support the City
Council’s inclusion of “City Finances” and “Environmental Sustainabilty” in the 2010 Council
Top 5 Priorities, and the recommendations of the Mayor’s Green Ribbon Task Force on Climate
Protection; and
WHEREAS, action on some of these issues may require active involvement of
Palo Alto elected and appointed officials; and
WHEREAS, the Utilities’ Legislative Policy Guidelines for 2011 were presented
to the UAC at its December 2, 2010 meeting, and the UAC voted 6 to 0 (with Commissioner
Keller absent) to recommend that the City Council approve the Utilities’ Legislative Policy
Guidelines with the changes recommended by the UAC.
NOW, THEREFORE, the Council of the City of Palo Alto does hereby
RESOLVE as follows:
SECTION 1. The Council hereby adopts the resolution approving the Utilities’
Legislative Policy Guidelines for 2011.
SECTION 2. The Council finds that any revenue derived from the authorized
adoption enumerated herein shall be used only for the purpose set forth in Article VII, Section 2,
of the Charter of the City of Palo Alto.
//
//
* NOT YET APPROVED*
2
110105 dm 6051482
SECTION 3. The Council finds that the adoption of this resolution does not
constitute a project under Section 21065 of the California Environmental Quality Act (CEQA)
and the CEQA Guidelines, and therefore, no environmental assessment is required.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
___________________________ ___________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
___________________________ ___________________________
Senior Deputy City Attorney City Manager
___________________________
Director of Utilities
___________________________
Director of Administrative
Services
ATTACHMENT B
Utilities’ Legislative Policy Guidelines for 2011
Advocacy positions taken in alignment with these guidelines will be subject to the approval of the
Utilities Director or City Manager as per the City’s legislative advocacy process
ALL UTILITIES
Goals
1. Preserve/enhance local accountability in the control and oversight of matters impacting utility
programs and rates for our customers while balancing statewide climate protection goals.
2. Support legislation that makes bold progress in cost effectively reducing greenhouse gas emissions,
and recognizes early voluntary action.
3. Support efforts to maintain or improve the reliability of the supply, transmission, storage and
distribution/collection infrastructures.
4. Maintain the City of Palo Alto Utilities’ (CPAU’s) ability to provide safe, reliable, sustainable, and
competitively-priced utility services.
Legislative Policy Guidelines Venue Goals
1. Local
Accountability
2. Climate
Protection
3. Reliability
&
Infrastructure
4.
Service
& Cost
Control
1. Advocate goals through active
participation in joint action efforts.
Federal, State,
and Regional
2. Communicate the City’s record on
environmental and energy efficiency
programs with Legislature, California
Energy Commission (CEC), California
Air Resources Board (CARB), and
Natural Resources Defense Council
(NRDC) via California Municipal
Utilities Association (CMUA),
Northern California Power Agency
(NCPA), and the Bay Area Water
Supply and Conservation Agency
(BAWSCA).
State
Utilities Legislative Policy Guidelines for 2011
1. Local
Accountability
2. Climate
Protection
3. Reliability
&
Infrastructure
4.
Service
& Cost
Control
3. Support legislation that will result in
the most cost-effective reduction of
GHG emissions, recognition of early
action, and inclusion of more efficient
solutions, such as cogeneration,
distributed resources, and demand
control programs, in integrated
resource plans.
Federal, State,
and Regional
4. Promote utility legislation and
regulation that support reasonable
reliability standards and compliance
requirements, and effective and
consistent reporting requirements,
customer communications, and goal-
setting.
Federal, State,
and Regional
Reliability
Councils
5. Oppose cost shifts from Federal or
State budgets and California Public
Utilities Commission (CPUC)
jurisdictional utilities through active
participation in CMUA and NCPA
legislative activities.
Federal, State,
and CPUC
6. Advocate for State and Federal grants
for local and regional applications of
energy efficiency, conservation,
renewable resources, fiber, wastewater
collection systems and recycled water
projects.
Federal and
State
7. Maintain right of way access for utility
infrastructure.
Federal and
State
8. Protect the value of existing contracts
and local regulatory approvals of such
contracts.
Federal and
State
Page 2 of 10
Utilities Legislative Policy Guidelines for 2011
WATER
Goals
1. Increase the security and reliability of the regional water system owned and operated by the San
Francisco Public Utilities Commission (SFPUC).
2. Maintain the provision of an environmentally sustainable, reliable supply of high quality water at a
fair price.
3. Support ability of municipal utilities to develop and manage their own conservation and efficiency
programs and retain authority over ratemaking, including the ability to optimize volumetric and fixed
charges to balance the goals of revenue certainty and water use efficiency.
4. Support efficiency and recycled water programs in order to minimize the use of imported supplies.
Legislative Policy Guidelines Venue Goals
1.
Reliable
infrastructure
2.
Supplies
at fair
cost
3. Local
Authority
4.
Minimize
imports
1. Advocate goals through active participation in
the Bay Area Water Supply and Conservation
Agency (BAWSCA) and California
Municipal Utilities Association (CMUA),
with support from Palo Alto staff for
BAWSCA and the San Francisco Bay Area
Regional Water System Financing Authority
(RFA).
Local,
Regional
& State
2. Participate in California Urban Water
Conservation Council (CUWCC) Best
Management Practice (BMP) revisions and
development to ensure that aggressive and
cost-effective efficiency goals are
incorporated and operating proposals are
reasonable, achievable, and cost-effective.
State
3. Advocate to ensure that legislative actions
regarding the Hetch Hetchy Reservoir and
conveyance system include the following
requirements:
timely rebuilding of the regional water
system;
maintains the quality of delivered water;
minimizes any increase in the cost of
water;
creates no additional exposure to more
frequent or severe water shortages;
supports the existing water system and its
operation.
Local,
Regional
& State
Page 3 of 10
Utilities Legislative Policy Guidelines for 2011
1.
Reliable
infrastructure
2.
Supplies
at fair
cost
3. Local
Authority
4.
Minimize
imports
4. Advocate for interpretations or
implementation of Water Code provisions
(such as those enacted by AB 1823 (2002),
AB 2058 (2002) and SB 1870 (2002)) that
maintain or reinforce the authorities and
protections available to the City and
BAWSCA members outside of San Francisco.
Local,
Regional,
and State
5. Support provision of sufficient resources for
BAWSCA to enable it to advocate for:
an environmentally sustainable, reliable
supply of high quality water at a fair
price;
preservation of Palo Alto’s existing
contractual water allocation and
transportation rights on the SFPUC Hetch
Hetchy system;
regional planning for conservation,
recycled water, and other water supply
projects.
Local and
Regional
6. Advocate for:
actions that preserve Palo Alto’s existing
contractual rights
supporting actions that preserve local
control over water use and limit
encroachment from outside jurisdictions
Local
and
Regional
7. Support infrastructure security and reliability
including an interconnection between the
SCVWD West Pipeline with the SFPUC’s
Bay Division Pipelines 3 and 4.
Regional,
and State
8. Support notification requirements that aid
residents/customers but do not inflict undue or
unobtainable requirements on the utility.
State
9. Support local control of public benefit funds
funding levels and program design.
State
10. Advocate for financing or funding for water
conservation programs and recycled water
projects that meet end-use needs and conserve
potable water.
Regional,
State and
Federal
Page 4 of 10
Utilities Legislative Policy Guidelines for 2011
GAS
Goals
1. Preserve /enhance the ability of municipal utilities to develop their own demand side efficiency and
conservation programs, alternative gas supplies, and rate structure.
2. Support efforts to reduce greenhouse gas emissions and protect the environment.
3. Increase the security and reliability of the gas supply and transmission infrastructure. This includes
retaining access to intra- and interstate gas transmission systems to reliably serve customers.
4. Preserve just and reasonable utility rates.
Legislative Policy Guidelines Venue Goals
1. Local
Authority
2.
Environ-
ment
3. Reliability
of
Infrastructure
4. Cost
Control
1. Advocate most of these goals mainly
through the American Public Gas
Association (APGA) with minor support
from Palo Alto staff.
Primarily
Federal with
minor
advocacy at
State level
2. Work with Northern California Power
Agency (NCPA) and California Municipal
Utilities Association (CMUA) to the extent
that the City’s goals as a gas distributor
align with generators’ use of natural gas.
Federal and
State
3. Support increased production/incentives
for renewable gas supplies.
Federal and
State
4. Advocate for financing or funding for
natural gas efficiency and solar water
heating end uses.
Federal and
State
5. Support market transparency and efforts to
eliminate market manipulation through
reasonable oversight
Federal
6. Support municipal utilities ability to enter
into pre-pay transactions for gas supplies.
Federal
Page 5 of 10
Utilities Legislative Policy Guidelines for 2011
ELECTRIC
Goals
1. Preserve /enhance the ability of municipal utilities to exercise local accountability and oversight over
matters impacting customer service, programs (such as demand side efficiency and conservation
programs), and rate structure.
2. Preserve/enhance the reliability and security of infrastructure.
3. Support legislation that makes bold progress in cost effectively reducing greenhouse gas emissions
and encourages early voluntary action.
4. Preserve just and reasonable utility rates/bills.
Legislative Policy Guidelines Venue Goals
1. Local
Accountability
2.
Reliability
3. GHG
Reduction
4. Cost
Control
1. Advocate goals through Northern California
Power Agency (NCPA), California Municipal
Utilities Association (CMUA), American Public
Power Association (APPA), Transmission
Agency of Northern California (TANC), and
Bay Area Municipal Transmission Group
(BAMx) with support from Palo Alto staff to
speak with a coordinated voice.
Federal
and State
2. Advocate for legislation/regulations that provide
local support for:
clean distributed generation and cogeneration
projects, and standards for connecting such
resources to the local distribution system;
electric efficiency programs;
implementation of renewable portfolio
standards;
storage integration;
smart grid design and implementation, and
control of public benefit funds (as allowed in
AB1890 (1996)).
Federal
and State
3. Support cap-and-trade market designs that:
protect consumers from the exercise of
market power;
allocate allowances that help mitigate
impacts to Palo Alto customers while
providing incentives for utilities to move to
lower GHG emission portfolios;
provide flexible compliance mechanisms
such as banking & borrowing of allowances.
Federal
and State
Page 6 of 10
Utilities Legislative Policy Guidelines for 2011
1. Local
Accountability
2.
Reliability
3. GHG
Reduction
4. Cost
Control
4. Support renewable portfolio standards that:
promote the 33% goal for the state;
maintain local compliance authority;
allow utilities to pursue low cost alternatives
by utilizing existing transmission system to
access out-of-state resources.
Local
and State
5. Support/encourage transmission, generation, and
demand-reduction projects and solutions
including advocating for financing or funding
solutions/options for projects that:
enhance/ensure reliability;
ensure equitable cost allocation (including
protection against imposition of state-owned
electric contract costs on municipal utility
customers);
improve procurement flexibility (e.g.
resource adequacy rules that ensure
reliability and provide flexibility or use of
Renewable Energy Certificates (RECs) in
meeting State renewable portfolio standards);
improve market transparency (particularly
transparency of IOU’s transmission and
procurement planning and implementation
activities); and
lower the environmental impact on the Bay
Area and the Peninsula.
Local,
State,
and
Federal
6. Advocate for Congressional, legislative, or
administrative actions on matters impacting
costs or operations of the Western Area Power
Administration such as:
support of Congressional Field Hearings to
explore modernizing flood control strategies,
river regulation and generation strategies at
CVP plants to enhance generation, water
delivery, flood control and fisheries;
protection of the status of Western Power
Marketing Administration and cost-based
rates; and
provisions for preference customers’ first
take at land available with economic
potential for wind farms.
Federal,
State and
Regional
Page 7 of 10
Utilities Legislative Policy Guidelines for 2011
1. Local
Accountability
2.
Reliability
3. GHG
Reduction
4. Cost
Control
7. Advocate for Congressional, legislative, or
administrative actions on matters relating to
overly burdensome reporting and compliance
requirements established by the North American
Reliability Corporation (NERC), the Federal
Energy Regulatory Commission (FERC) or the
Western Electricity Coordinating Council
(WECC).
Federal,
State and
Regional
8. Seek Congressional remedies (if needed) for
punitive application of fees and fines established
by NERC, WECC, or FERC.
Federal
and
Regional
9. Work with California Independent System
Operator (CAISO) or through FERC:
to give buyers of renewable intermittent
resources relief from imbalance penalties;
and
to promote financial and operational changes
that result in timely and accurate settlement
and billing.
Federal
and State
Page 8 of 10
Utilities Legislative Policy Guidelines for 2011
WASTEWATER COLLECTION
Goals
1. Increase the reliability of the local wastewater collection systems.
2. Maintain the provision of an environmentally sustainable, reliable high quality wastewater collection
service at a fair price.
3. Support ability of municipal utilities to develop and manage their own conservation and efficiency
programs and retain authority over ratemaking, including the imposition of non-volumetric customer
meter or infrastructure charges for wastewater collection service.
4. Support equal comparisons of wastewater collection system with regard to regulations in order to
minimize and reduce onerous, costly and time-intensive reporting requirements and improve value
and accuracy of information reported to the public.
Legislative Policy Guidelines Venue Goals
1.
Reliable
infrastructure
2.
Maintain
service
3. Local
Authority
4.Valuable
Reporting
1. Advocate goals through active
participation in the Association of Bay
Area Governments (ABAG).
Local,
Regional
& State
2. Advocate to ensure that legislative
actions regarding the comparison of
wastewater collections systems for
future regulations include the following
requirements:
timely rebuilding of the local
wastewater systems;
maintains the quality of delivered
wastewater collection service;
minimizes any increase in the cost of
wastewater collection service;
creates no additional exposure to
more frequent or severe wastewater
overflows;
supports the existing wastewater
collections systems and their
operation.
Local,
Regional
& State
3. Support provision of sufficient
resources for ABAG to enable it to
advocate for:
environmentally sustainable, reliable
wastewater collection service at a
fair price;
regional comparisons of wastewater
Local
and
Regional
Page 9 of 10
Utilities Legislative Policy Guidelines for 2011
Page 10 of 10
1.
Reliable
infrastructure
2.
Maintain
service
3. Local
Authority
4.Valuable
Reporting
collection projects for future state
grant funding.
4. Support infrastructure security and
reliability including equitable allocation
of funds for increasing the security of
infrastructure.
Regional,
and State
5. Advocate for funding for wastewater
collections system projects that reduce
overflows and improve collection system
efficiency.
Regional,
State and
Federal
Utilities Advisory Commission Minutes Approved on: Page 1 of 1
DRAFT
UTILITIES ADVISORY COMMISSION
EXCERPT MINUTES OF DECEMBER 1, 2010
ITEM 3: ACTION ITEM: Utilities Legislative Policy Guidelines for 2011
Acting Assistant Director Debra Lloyd presented the Utilities Department’s proposed Legislative Policy Guidelines for
2011. Lloyd explained the reason for the guidelines, to provide direction in evaluating and responding promptly to
legislative action involving utilities and utilities’ issues throughout the year and to clarify approved policy and
advocacy direction when active involvement of Palo Alto elected officials is required. Then she highlighted the
changes to goals and guidelines from those approved in 2010 that are proposed to respond to anticipated legislative
focus in 2011.
The Commissioners made further amendments to the goals and the guidelines through the presentation. The “All
Utilities” goals were amended to include a reference to storage and safety issues. An additional guideline was added
to protect the value of existing contracts, which was a guideline originally stated in the electric utility section but that
the UAC suggested was a priority that applied to all utilities.
For the Water Utility guidelines the Commissioners discussed the relevance of guidelines for interactions with other
agencies that are more operational in nature rather than legislative. Commissioner Berry suggested that language
should allow for legislative remedies while avoiding language that would curtail the City’s ability to pursue legal
remedies, so changes were made to guideline 6 to make it more generally applicable to potential legislative
remedies. Staff was directed to review this language again with the City Attorney’s office. Commissioner Berry
suggested changes to Guideline 8 to make it more general to refer to notification requirements to any residents.
The UAC made no changes to the Natural Gas utility goals and guidelines but Commissioner Foster did ask for
clarification on the change of language in Guideline 4 that the proposal is to advocate for financing or funding for
efficiency programs, which could be from state or federal grants or from local funding.
For the Electric Utility guidelines, the Commissioners discussed the language proposed for the allocation of GHG
emissions allowances under a cap-and-trade market in guideline 3. To make the guideline more focused on
protecting Palo Alto customers the language was changed to “Support cap-and-trade market designs that allocate
allowances that help mitigate impacts to Palo Alto customers while providing incentives for utilities to move to lower
GHG emission portfolios.” The Commissioners also discussed the new guideline 4 to support the 33% RPS goal for
the state while allowing utilities to use out-of-state resources to meet that goal. Staff explained that although Palo Alto
may meet its goal with in state resources, any restrictions on how other utilities met their targets could require
expensive transmission infrastructure investments, the costs of which would be shared by everyone, including Palo
Alto. No changes were recommended to the proposed language for Electric guideline 4. Chair Waldfogel suggested
that the Electric guideline 9 regarding protecting the value of existing contracts could be more generally applied to all
utilities and the UAC agreed that this should be moved to the All Utilities section.
Lloyd provided an overview of the goals and guidelines for the new section added for the Wastewater Collection
utility. There was no discussion on these guidelines and no changes proposed.
ACTION:
Commissioner Eglash made a motion to recommend Council approval of the Utilities Legislative Policy Guidelines for
2011 with changes proposed by the UAC. Commissioner Cook seconded the motion. The motion carried
unanimously (6-0) with Commissioner Keller absent.