HomeMy WebLinkAboutStaff Report 7677
City of Palo Alto (ID # 7677)
City Council Staff Report
Report Type: Consent Calendar Meeting Date: 2/13/2017
City of Palo Alto Page 1
Summary Title: Utilities 2017 Legislative Guidelines
Title: Adoption of a Resolution Approving the 2017 City of Palo Alto Utilities
Legislative Policy Guidelines
From: City Manager
Lead Department: Utilities
RECOMMENDATION
Staff and the Utilities Advisory Commission (UAC) recommends that Council adopt the attached
resolution (Attachment A) approving amendments to the Utilities Legislative Policy Guidelines,
as recommended by the UAC on January 11, 2017.
EXECUTIVE SUMMARY
Each year, Utilities Department staff drafts legislative and regulatory guidelines reflecting
forthcoming and historical issues and priorities. These draft guidelines are reviewed by the UAC
prior to moving to the City Council for approval. This year, at its January 11, 2017 meeting, the
UAC reviewed and voted unanimously to recommend that Council approve the amended
guidelines.
BACKGROUND
The utility industry is a high-profile and heavily regulated industry subject to continuous
legislative action at both the state and federal levels. Such legislation can influence, among
other things, the reliability and security of the supply and distribution infrastructure, customer
service and billing, program design, rate design, and activities and costs associated with climate
protection. Recognizing the high-profile and subject-specific nature of the utilities industry and
the fast past of the legislative and regulatory process, the Utilities Department annually
prepares a set of guidelines for review and approval by both the UAC and the City Council.
The Utilities Legislative Guidelines were drafted parallel to the City’s Legislative Priorities and
Legislative Program Manual (2017 update), as approved the Policy and Services Committee on
November 29, 2016. The Guidelines contain complementary goals such as preserving and
enhancing local accountability and oversight, ensuring system/program reliability, and
preserving reasonable rates. These Utilities department-specific priorities are intended to
City of Palo Alto Page 2
operate in conjunction with the City’s priorities, and are consistent with the City’s overarching
legislative principles.
DISCUSSION
The proposed Utilities Legislative Policy Guidelines (Exhibit 1) were updated to respond to
recent legislative and regulatory trends. At its January meeting, the Commission discussed
whether the policies covered regulatory advocacy in addition to legislative and whether they
provided staff with the ability to respond to federal legislative proposals. The Commission also
discussed Western issues, both the Central Valley Project and regionalization of the California
energy markets. After discussion, the UAC voted to recommend approval of the 2017
Legislative Guidelines as modified by:
(1) Moving the guideline “support infrastructure and reliability, including equitable allocation of
funds for increasing the security of infrastructure” from the suggested Wastewater category
to the All Utilities category; and
(2) Ensuring the Fiber category reflected the appropriate “dig once” wording.
Staff incorporated those changes to Exhibit 1. Attachment A is the resolution for Council’s
consideration, Attachment B is the redlined version of the 2017 update, and Attachment C is
the draft minutes of the UAC meeting.
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 Council policy and supports the Utilities Strategic Plan’s
objectives of: ensuring a reliable and safe supply of utility resources, providing customer service
excellence, managing costs, and ensuring environmental sustainability.
ENVIRONMENTAL REVIEW
The Council’s adoption of a resolution adopting the Utilities Legislative Policy Guidelines is not a
project requiring California Environmental Quality Act (CEQA) review, under California Public
Resources Code Sec. 21065, 21080(b)(8), and CEQA Guidelines Section 15378(b)(5), because it is
an administrative governmental activity which will not cause a direct or indirect physical change
in the environment.
Attachments:
Exhibit 1: 2017 Utilities Legislative Guidelines
Attachment A: RESO Legislative Guidelines
Attachment B: Changes from 2016 guidelines
Attachment C: Draft Minutes of the January 11 UAC Special Meeting
Utilities Legislative Policy Guidelines January 2017 Update
Page 1 of 16
EXHIBIT 1
Approved by City Council on February 13, 2017; Resolution #---
Utilities’ Legislative Policy Guidelines
Formal advocacy positions taken in alignment with these guidelines will be subject to the
approval of the Utilities General Manager or City Manager.
ALL UTILITES
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 efforts to maintain or improve the reliability of the supply, transmission, storage and
distribution/collection infrastructures.
3.Support government action that makes bold progress in cost effectively reducing greenhouse gas
(GHG) emissions, supporting electrification efforts, and recognizes early voluntary action advancing
both.
4.Maintain the City of Palo Alto Utilities’ (CPAU’s) ability to provide safe, reliable, sustainable, and
competitively-priced utility services.
Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountability
2. Reliability
&
Infrastructure
3. Climate
Protection
4. Service &
Cost
Control
1.Advocate goals through active
participation in joint action
efforts, including supporting the
efforts of common goals
through external organizations
Federal,
State, and
Regional
2.Support legislation that results in
locally designed, cost-effective
and efficient solutions to the goal
of GHG emissions reductions.
Federal,
State, and
Regional
3.Promote legislation and
regulations that have
undergone stakeholder review
and cost benefit analysis to
support effective and consistent
reporting requirements,
customer communications, and
program results
Federal,
State, and
Regional
Reliability
Councils
Utilities Legislative Policy Guidelines January 2017 Update
Page 2 of 16
Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountability
2. Reliability
&
Infrastructure
3. Climate
Protection
4. Service &
Cost
Control
4.Oppose unreasonable and
inequitable financial burdens and
support policy changes that assist
customers through active
participation in the legislative
activities of the Northern
California Power Agency (NCPA)
and the California Municipal
Utilities Association (CMUA).
Federal,
State, and
CPUC
5.Advocate for state and federal
grants for local and regional
energy efficiency and
conservation measures,
renewable resources, fiber, fuel
switching, wastewater collection
systems and recycled water
projects.
Federal
and State
6. Maintain right of way access for
utility infrastructure.
Federal and
State
7.Protect the value of existing
assets and contracts and local
regulatory approvals of same.
Federal
and State
8. Support government action
allowing CPAU to maintain
customer confidentiality.
State
9.Maintain existing low cost
municipal financing options for
infrastructure projects and
advocate for new federal and
state programs that recognize
critical infrastructure needs.
Federal
and State
10.Promote utility legislation and
regulations that support
reasonable and consistent
notification, compliance, and
reporting requirements for
operations, services,
communications, billing and
payments.
Federal
and State
Utilities Legislative Policy Guidelines January 2017 Update
Page 3 of 16
Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountability
2. Reliability
&
Infrastructure
3. Climate
Protection
4. Service &
Cost
Control
11. Through Account
Representatives, educate key
customer accounts about
significant policy actions that
could affect their business
Local
12. Oppose government action that
could adversely impact our
customers or that include
mandates we could not
reasonably achieve.
Federal
and State
13.Support cap-and-trade
market designs that:
protect consumers from
the exercise of market
power;
allocate allowances that
mitigate impacts to Palo Alto
customers while preserving
City environmental goals;
advocate for an allowance
allocation methodology that
provides flexibility for Palo
Alto to structure rates to align
GHG costs and revenues;
provide flexible compliance
mechanisms such as banking
and borrowing of
allowances; and
allocate funds generated
from cap-and-trade markets
to GHG related activities, not
as a revenue source for state
or federal general funds.
State
14.Support infrastructure
security and reliability
including equitable
allocation of funds for
increasing the security of
infrastructure.
Regional/
State
Utilities Legislative Policy Guidelines January 2017 Update
Page 4 of 16
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, local oversight, and security of infrastructure.
3.Support legislation that recognizes early voluntary action to combat climate change including
initiatives to reduce GHG emissions and specifically exempts a municipality from
burdensome requirements in subsequent legislation that could result from the early action.
4.Preserve just and reasonable utility rates/bills established by local governing bodies.
Goals
Legislative Policy Guidelines Venue
1. Local
Accountability
2.
Reliability
3. GHG
Reduction
4. Cost
Control
1.Advocate goals through NCPA, CMUA,
American Public Power Association (APPA),
Transmission Agency of Northern California
(TANC), and the Bay Area Municipal
Transmission Group (BAMx) with support from
Palo Alto staff to speak with a coordinated
voice.
Federal and
State
2.Support NCPA in its continued efforts to
streamline state regulatory reporting
responsibilities, to eliminate duplicative data
and report submittals to multiple state
regulatory agencies, including the CEC, CARB,
and the California Independent System
Operator (CAISO).
State
3.Advocate for legislation/regulations that
provide local accountability and support for:
locally-designed and implemented solar
programs and rates
development of long-term plans and
reasonable and flexible integrated
resource planning requirements
development of distributed energy
resources and plans, and standards and
permitting requirements for connecting
such resources to the local distribution
system;
transparent and consistent accounting
and reporting of CHG emissions and
portfolio content;
balancing state and local policy
Federal and
State
Utilities Legislative Policy Guidelines January 2017 Update
Page 5 of 16
Goals
Legislative Policy Guidelines Venue
1. Local
Accountability
2.
Reliability
3. GHG
Reduction
4. Cost
Control
implementation and ratepayer equity;
equitable rate design and tariffs;
cost-effective electric efficiency and
demand-side management programs;
implementation of renewable portfolio
standards in a reasonable manner;
cost-effective and locally beneficial
storage;
direct access;
advanced meters and smart grid design and
implementation;
use of public benefit funds (as allowed in
AB 1890 (1996); and
Electrification, including electric vehicle
infrastructure
4.Support legislation for renewable portfolio
standards that:
maintain local compliance authority;
avoid mandates for technology or source
specific carve outs;
allow utilities to pursue the most cost
effective resources available to meet
portfolio needs including use
of Renewable Energy Certificates (RECs);
ensure fair application of RPS standards,
avoiding punitive and/or duplicative non-
compliance penalties;
restrict extension of CEC jurisdiction and
attempts of the CPUC to claim jurisdiction
or obtain de facto jurisdiction over
Publicly Owned Utilities;
allow local distributed generation to
count in full towards RPS; and
prioritize the use of the existing
transmission system over building new
transmission.
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 following
beneficiary pays principles (including
protection against imposition of state-
Local, State,
and Federal
Utilities Legislative Policy Guidelines January 2017 Update
Page 6 of 16
Goals
Legislative Policy Guidelines Venue
1. Local
Accountability
2.
Reliability
3. GHG
Reduction
4. Cost
Control
owned electric contract costs on municipal
utility customers);
improve procurement flexibility (e.g.
resource adequacy rules that ensure
reliability and provide flexibility in meeting
operational requirements or flexibility in
meeting State renewable portfolio
standards);
support the continuation of federal and
state financial incentives that promote
increased renewable development;
improve market transparency (particularly
transparency of IOU’s transmission and
procurement planning and
implementation); and
reduce the environmental impact on
the Bay Area and the Peninsula.
6.Advocate for actions on matters impacting
the Western Area Power Administration
(Western) such as:
support Congressional hearings to explore
modernizing regulation and generation
strategies at Central Valley Project (CVP)
plants to enhance generation, water
delivery, flood control and fisheries;
protection of the status of Western Power
Marketing Administration and cost-based
rates;
provisions for preference customers’ first
take at land available with economic
potential for wind farms;
balancing efforts for competing
environmental improvements in rivers and
Delta conditions with water supply and
hydropower impacts without
compromising the primary mission of
Western and recognizing the achievements
already made in California without adding
duplicate costly efforts;
monitoring and evaluating impacts of Delta
conveyance proposals on Western Base
Resource allocation; and
advocating for an equitable distribution of
costs between water and power customers
of the Central Valley Project.
Federal,
State and
Regional
Utilities Legislative Policy Guidelines January 2017 Update
Page 7 of 16
Goals
Legislative Policy Guidelines Venue
1. Local
Accountability
2.
Reliability
3. GHG
Reduction
4. Cost
Control
advocating for clear product provisions,
fair allocation of Base Resource Capacity
and fair contract terms under Western’s
2025 Power Marketing Plan and new
Western Base Resource contracts.
7.Advocate for 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)
and the Western Electricity Coordinating
Council (WECC).
Federal,
State and
Regional
8.Support fair and reasonable application of grid
reliability requirements established by NERC,
WECC, and FERC and seek appropriate
remedies (if needed) for punitive application
of fees and fines.
Federal and
Regional
9.Work with CAISO and/or FERC:
to give buyers of renewable intermittent
resources relief from imbalance penalties;
to promote financial and operational
changes that result in timely and accurate
settlement and billing; and
to provide critical input on the need for
various transmission projects in light of the
escalating costs to the City to import power
using the bulk transmission system.
Federal and
State
10.Monitor cyber security issues to ensure that
CPAU, which currently does not have critical
cyber assets, retains local control over its
cyber security needs while remaining exempt
from NERC cyber security standards. Support
NCPA to protect it and its member agencies
from unnecessary cyber security regulations.
Federal and
Regional
Utilities Legislative Policy Guidelines January 2017 Update
Page 8 of 16
FIBER OPTIC
Goals
1.Preserve and enhance the authority of local government to (1) develop broadband solutions that align
with community needs and (2) expand consumer choice for competitive Internet connectivity and
other advanced services delivered over fiber-optic networks.
2.Encourage the competitive delivery of broadband services by permitting the use of public rights-of-
way and Utilities infrastructure in a responsible manner, provided that local rights of way authority
and management is preserved and the use does not compromise the City’s existing utility safety and
services obligations.
3.Support local government authority over zoning-related land use for communications infrastructure
in accordance with reasonable and non-discriminatory regulations.
4.Support the Council’s Technology and the Connected City initiative to fully leverage the City’s fiber-
optic asset to provide ubiquitous and reliable ultra-high-speed broadband connectivity.
Goals
Legislative Policy Guidelines Venue
1.Support
Municipal
Delivery
2. Competitive
Delivery
3. Local
Authority
over Land
Use
4. Support
Council
Initiatives
1.Advocate for these goals through the
APPA, CMUA, National Association of
Telecommunications Officers and
Advisors (NATOA), National League of
Cities (NLC), and the Next Century
Cities initiative (NCC), with support
from City staff.
Federal
and State
2.Support legislation and regulations that
preserve and enhance municipal
delivery of conventional and advanced
telecommunication services as
prescribed by the Telecommunications
Act of 1996.
Federal
and State
3.Support the goals of the Federal
Communications Commission’s (FCC),
National Broadband Plan to improve
Internet access nationwide.
Federal
and State
4.Oppose legislation and regulations that
benefit the incumbent cable TV and
telephone companies at the expense of
community-owned fiber-optic and
wireless networks.
Federal
and State
5.Support legislation and regulations that
preserve and enhance consumer
protections related to the incumbent
providers of telecommunication
Federal
and State
Utilities Legislative Policy Guidelines January 2017 Update
Page 9 of 16
Goals
Legislative Policy Guidelines Venue
1.Support
Municipal
Delivery
2. Competitive
Delivery
3. Local
Authority
over Land
Use
4. Support
Council
Initiatives
services.
6.Continue to support the Council’s
municipal fiber and wireless
initiatives.
Local
7.Support legislation and regulations
that:
Permit the use of public right-of-
way and Utilities infrastructure;
Preserve local rights-of-way
authority and management;
Preserve local government zoning
and siting authority for wireless
and wireline communication
facilities;
Support local “dig once” policies
to deploy infrastructure such as
communications conduit for
future fiber and wireless networks
capable of delivering next-
generation broadband services
Oppose legislation and regulations
that reduce compensation
received by local governments for
the use of the public rights-of-way
and other public properties that
support communication
infrastructure .
Federal,
State and
Local
Utilities Legislative Policy Guidelines January 2017 Update
Page 10 of 16
NATURAL 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.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.
3.Support efforts to reduce greenhouse gas emissions and protect the environment.
4.Preserve just and reasonable utility rates/bills established by local governing bodies.
Goals
Legislative Policy Guidelines Venue 1. Local
Accountability
2. Reliability of
Infrastructure
3. Environ-
ment
4. Cost
Control
1.Leverage the American Public Gas
Association (APGA) to assist in
natural gas goals .
Primarily
Federal with
minor
advocacy at
State level
2.Work with NCPA and 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 cost effective renewable
gas supplies from in or out of state
sources. Advocate for locally
reasonable mandated renewable
portfolio standards.
Federal and
State
4.Advocate for financing or funding
for cost-effective 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
7.Support efforts to improve pipeline
safety.
Federal and
State
8.Work with partners to discourage
extension of CPUC regulatory
authority over municipal gas
operations.
State
Utilities Legislative Policy Guidelines January 2017 Update
Page 11 of 16
Goals
Legislative Policy Guidelines Venue 1. Local
Accountability
2. Reliability of
Infrastructure
3. Environ-
ment
4. Cost
Control
9.Oppose legislative proposals
resulting in unreasonable costs for
Palo Alto’s customers.
Federal
and State
10.Support legislation that aims to
protect public health and
encourages transparency
regarding hydraulic fracturing or
“fracking” for natural gas
development, while opposing
blanket moratoriums that aren’t
supported by science.
Federal
and State
Utilities Legislative Policy Guidelines January 2017 Update
Page 12 of 16
WASTEWATER COLLECTION
Goals
1.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.
2.Encourage efforts to increase the reliability of the local wastewater collection systems.
3.Maintain the provision of reliable and sustainable wastewater collection service at a fair price.
4.Support equal comparisons of wastewater collection systems by regulatory agencies in order to
minimize and reduce onerous, costly, time-intensive reporting requirements and improve value
and accuracy of information reported to the public.
Goals
Legislative Policy Guidelines Venue
1. Local
Accountability
2. Reliable
Infrastructure
3. Maintain
service
4. Valuable
reporting
1.Advocate goals through active
participation in the Association of
Bay Area Governments (ABAG),
and CMUA.
Local,
Regional
& State
2.Support regulations of wastewater
collection systems that recognize:
local jurisdictions’ proactive
efforts to replace and maintain
wastewater collections
systems;
the need to provide affordable
and cost based collection
service; and
the unique characteristics of
each collection system.
Local,
Regional
& State
3.Support provision of sufficient
resources for regional agencies to
enable them to advocate for:
environmentally sustainable,
reliable wastewater collection
service at a fair price; and
regional comparisons of
wastewater collection projects
for future state grant funding.
Local and
Regional
4.Advocate for funding and local
regulations for wastewater
collections system projects and
requirements that reduce
overflows and improve collection
system efficiency.
Regional,
State and
Federal
Utilities Legislative Policy Guidelines January 2017 Update
Page 13 of 16
WATER
Goals
1.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.
2.Increase the security and reliability of the regional water system owned and operated by the San
Francisco Public Utilities Commission (SFPUC).
3.Support efficiency and recycled water programs in order to minimize the use of imported supplies.
4.Maintain the provision of an environmentally sustainable, reliable supply of high quality water at a
fair price.
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
1.Advocate goals through active
participation in the Bay Area Water Supply
and Conservation Agency (BAWSCA) and
CMUA, with support from Palo Alto staff
for BAWSCA.
Local,
Regional
and State
2.Advocate to ensure that legislative actions
regarding the Hetch Hetchy Regional
Water System include:
timely rebuilding of the regional water
system;
assurance that the SFPUC is
adequately assessing and
mitigating risks of infrastructure
failure;
maintenance of the quality of
delivered water;
minimization of any increase in the
cost of water;
no additional exposure to more
frequent or severe water
shortages;
support for the existing water system
and its operation.
Local,
Regional
and State
3.Advocate for interpretations or
implementation of Water Code provisions
that maintain or reinforce the authorities
and protections available to the City and
BAWSCA members outside of San
Francisco.
Local,
Regional
and State
Utilities Legislative Policy Guidelines January 2017 Update
Page 14 of 16
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
4 .Support BAWSCA in efforts to achieve:
an environmentally sustainable,
reliable supply of high quality water at
a fair price;
a SFPUC rate structure that is
consistent with the Water Supply
Agreement and is based on water
usage;
a contract amendment to modify the
drought time water allocation
between the SFPUC and the BAWSCA
agencies;
preservation of Palo Alto’s existing
contractual water allocation and
transportation rights on the SFPUC
Hetch Hetchy system; and
regional planning for conservation,
recycled water, and other water supply
projects.
Local and
Regional
5.Advocate for actions that:
preserve Palo Alto’s existing
contractual rights;
preserve local control over water
use; and
limit encroachment from outside
jurisdictions.
Local and
Regional
6.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
7.Support notification requirements that
inform residents/customers but do not
inflict undue or unobtainable requirements
on the utility.
State
8.Support local control of public benefit
funding levels and program design.
State
9.Support beneficiary pays methodologies to
prevent taxes or fees imposed on SFPUC
customers to fund infrastructure
improvements and costs of water sources
that do not serve Palo Alto customers.
State and
Regional
Utilities Legislative Policy Guidelines January 2017 Update
Page 15 of 16
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
10.Advocate for financing, funding, and,
where applicable, tax exemption, for water
conservation programs, water rebate
programs, and recycled water projects that
meet end-use needs and conserve potable
water; oppose legislation that would
reduce such funding.
State,
Regional
and
Federal
11.Support legislation that promotes
responsible groundwater management.
State
12.Support Proposition 218 reform efforts to
provide ratemaking flexibility to balance
preservation, revenue sustainability, and
low income programs.
State
13.Advocate for water conservation policies
(both drought response and long term)
that achieve water sustainability while
minimizing customer and commercial
impact, protecting the City’s urban
canopy and minimizing the City’s
enforcement costs.
Local and
State
14.Protect SFPUC’s water rights.Local and
State
15.Support legislation that would protect the
City’s infrastructure and treatment
investments from future state-wide cuts
in water use.
State
16. Oppose government action that creates
undue burdens on or unreasonably
expands the role and responsibility of
water suppliers.
State
Not Yet Approved
170131 jb 6053903 January 2017 Update
Resolution No. _____
Resolution of the Council of the City of Palo Alto Approving the City of Palo Alto
Utilities’ Legislative Policy Guidelines
R E C I T A L S
A. The City of Palo Alto Utilities Strategic Plan (“Strategic Plan”), approved by the
Palo Alto City Council on July 18, 2011, [Staff Report #1880], and amended on August 5, 2013
(Staff Report #3950), provides a set of Strategic Objectives for the City of Palo Alto Utilities
Department (CPAU) to follow in ensuring a reliable and safe supply of utility resources,
providing customer service excellence, managing costs, and ensuring environmental
sustainability.
B. CPAU annually identifies Utilities’ Legislative Policy Guidelines that facilitate the
Strategic Plan’s Strategic Objectives, and advocates for utility-related issues at Federal and
State legislative forums in furtherance of those objectives.
C. Action on some of these issues may require active involvement of Palo Alto
elected and appointed officials.
D. The Utilities’ Legislative Policy Guidelines were presented to the UAC at its
January 11, 2017 meeting, and the UAC voted unanimously to recommend that the City Council
approve the Utilities’ Legislative Policy Guidelines.
The Council of the City of Palo Alto hereby RESOLVES as follows:
SECTION 1. The Council hereby adopts the resolution approving the Utilities
Legislative Policy Guidelines, effective February 13, 2017. All prior versions of the City of Palo
Alto Utilities Legislative Policy Guidelines are hereby repealed and replaced in their entirety by
the Utilities Legislative Policy Guidelines, attached to this Resolution as Exhibit 1.
SECTION 2. Staff will review the Guidelines annually and any proposed changes will
be approved by City Council.
SECTION 2. The Council finds that the adoption of this resolution is not a project
requiring California Environmental Quality Act (CEQA) review, under California Public Resources
ATTACHMENT A
Not Yet Approved
170131 jb 6053903 January 2017 Update
Code Sec. 21065, 21080(b)(8), and CEQA Guidelines Section 15378(b)(5), because it is an
administrative governmental activity which will not cause a direct or indirect physical change in
the environment.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
___________________________ ___________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
___________________________ ___________________________
Senior Deputy City Attorney City Manager
___________________________
Asst. City Manager/Utilities General Manger
___________________________
Director of Administrative Services
Utilities Legislative Policy Guidelines Utilities Legislative Policy Guidelines Janu
Page 1 of 22
EXHIBIT A
Approved by City Council on January XX, 2017; Resolution #---
Utilities’ Legislative Policy Guidelines
Formal advocacy positions taken in alignment with these guidelines will be subject to the approval
of the Utilities General Manager or City Manager as per the City’s Legislative Program Manual.
ALL UTILITES
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 efforts to maintain or improve the reliability and security of the supply, transmission, storage,
and distribution/collection, and data infrastructures.
3.Support legislationgovernment action that makes bold progress in cost effectively reducing greenhouse
gas (GHG) emissions, , supporting electrification efforts, and recognizes without penalizing early
voluntary action, and supports statewide climate protection goals advancing both.
4.Maintain the City of Palo Alto Utilities’ (CPAU’s) ability to provide safe, reliable, sustainable, and
competitively-priced utility services.
Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountability
2. Reliability,
Security
&
Infrastructure
3. Climate
Protection
4. Service & Cost
Control
1.Advocate goals through active
participation in joint action
efforts., including supporting
the efforts of common goals
through external
organizations
Federal,
State, and
Regional
2.Support legislation that allows
local evaluationresults in locally
designed, cost-effective and
design of more efficient energy
solutions, fuel switching, and
demand control programs to
the goal of GHG emissions
reductions.
Federal,
State, and
Regional
ATTACHMENT B
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Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountability
2. Reliability,
Security
&
Infrastructure
3. Climate
Protection
4. Service & Cost
Control
3. Promote utility legislation and
regulations that have
undergone stakeholder review
and cost benefit analysis to
support effective and
consistent compliance and
reporting requirements.
Ensure such legislation,
customer communications,
and regulations have received
stakeholder review and cost
benefit analysis.program
results
Federal,
State, and
Regional
Reliability
Councils
4. Oppose unreasonable and
inequitable financial burdens
and support policy changes
that assist customers through
active participation in CMUA
and NCPAthe legislative
activities. of the Northern
California Power Agency
(NCPA) and the California
Municipal Utilities Association
(CMUA).
Federal,
State, and
CPUC
5. Advocate for state and federal
grants for local and regional
energy efficiency and
conservation measures,
renewable resources, fiber
optic, fuel switching,
wastewater collection systems
and recycled water projects.
Federal
and State
6. Maintain right of way access for
utility infrastructure.
Federal and
State
7. Protect the financial and
operational value of
utilityexisting assets and
contracts; preserve and
local regulatory
controlapprovals of
bothsame.
Federal
and State
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Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountability
2. Reliability,
Security
&
Infrastructure
3. Climate
Protection
4. Service & Cost
Control
8. Enhance utilitySupport
government action allowing
CPAU to maintain customer
protections for data security
and confidentiality.
Federal
and State
9. Maintain existing low cost
municipal financing options for
infrastructure projects and
advocate for new federal and
state programs that recognize
critical infrastructure needs.
Federal
and State
10. Oppose government action
that could adversely impact
our customers or that include
mandates we could not
reasonably achieve.
Federal
and State
11. Promote utility legislation
and regulations
supportingthat support
reasonable and consistent
notification, compliance, and
reporting requirements for
utility notifications, ,
safetyoperations, services,
public communications,
billing, and payments, and
customer assistance.
Federal
and State
12. Through Account
Representatives, educate key
customer accounts about
significant policy actions that
could affect their business
Local
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Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountability
2. Reliability,
Security
&
Infrastructure
3. Climate
Protection
4. Service & Cost
Control
13. 11. Support Proposition 26
reform efforts to provide
ratemaking flexibility to
balance conservation,
revenue sustainability, and
low income assistance
programs.Oppose
government action that could
adversely impact our
customers or that include
mandates we could not
reasonably achieve.
Federal
and State
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Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountability
2. Reliability,
Security
&
Infrastructure
3. Climate
Protection
4. Service & Cost
Control
14. Support cap-and-trade
market designs that:
• protect consumers from
the exercise of market
power;
• allocate allowances that
mitigate impacts to Palo
Alto customers while
preserving City
environmental goals;
• advocate for an allowance
allocation methodology that
provides flexibility for Palo
Alto to structure rates to
align GHG costs and
revenues;
• provide flexible
compliance mechanisms
such as banking and
borrowing of allowances;
and
• allocate funds generated
from cap-and-trade
markets to GHG related
activities, not as a revenue
source for state or federal
general funds.12. Seek
state and regional funding
to enhance the efficiency,
security, and reliability of
infrastructure that
maintains utility customer
data security and
confidentiality.
Federal
and State
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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, local oversight, and security of infrastructure.
3. Support legislation that recognizes early voluntary action in reducingto combat climate change
including initiatives to reduce GHG emissions and specifically exempts a municipality from
burdensome requirements in subsequent legislation that could result from the early action.
4. Preserve just and reasonable utility rates/bills established by local governing bodies.
Goals
Legislative Policy Guidelines
Venue
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 the
Bay Area Municipal Transmission Group
(BAMx) with support from Palo Alto staff;
strive to present the same or substantially the
same messagespeak with a coordinated voice.
Federal and
State
2. Support NCPA in its continued efforts to
streamline the state regulatory reporting
responsibilities, to eliminate duplicative data
and report submittals to multiple state
regulatory agencies, including the CEC, CARB,
and the California Independent System
Operator (CAISO).
State
3. Advocate for legislation/regulations that
provide local accountability and design
ofsupport for:
• Net Energy Metering (NEM) successor
programs designed to fit local conditions
and priorities;
• Electric Integrated Resource Plans
• cost-effective renewablelocally-designed
and implemented solar programs and
rates
• development of long-term plans and
reasonable and flexible integrated
resource planning requirements
• development of distributed
Federal and
State
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Goals
Legislative Policy Guidelines
Venue
1. Local
Accountability
2. Reliability 3. GHG
Reduction
4. Cost
Control
generationenergy resources and
cogeneration projectsplans, and standards
and permitting requirements for
connecting such resources to the local
distribution system;
• transparent and consistent accounting
and reporting of GHG emissions and
portfolio content;
• balancing state and local policy
implementation and ratepayer equity;
• equitable rate design and tariffs;
• cost-effective electric efficiency and
demand-side management programs;
• implementation of renewable portfolio
standards in a reasonable manner;
• cost-effective and locally beneficial storage
integration;
• direct access requirements;
• smartadvanced meters and smart grid
design and implementation; and
• use of public benefit funds (as allowed in
AB 1890 (1996)); and
• Electrification, including electric vehicle
infrastructure
4. 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 lower
GHG emission portfolios;
• provide flexible compliance mechanisms
such as banking and borrowing of
allowances; and
• allocate funds generated from cap-and-
trade markets to cost-effective GHG-
reduction related activities, not as a
revenue source for state or federal general
funds.
Federal and
State
5.4. Support legislation for renewable portfolio
standards that:
• maintain local compliance authority;
• avoid mandates for technology or source
specific carve outs, and minimum term
Local and
State
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Goals
Legislative Policy Guidelines
Venue
1. Local
Accountability
2. Reliability 3. GHG
Reduction
4. Cost
Control
requirements;
• allow utilities to pursue allthe most cost-
effective resources available to meet
portfolio needs including use
• of Renewable Energy Certificates
(RECs);
• ensure uniformfair application of RPS
standards, avoiding punitive and/or
duplicative non-compliance penalties;
• restrict new regulations
expandingextension of CEC jurisdiction
and attempts of the CPUC to claim
jurisdiction or obtain de facto jurisdiction
over publicly owned utilitiesPublicly
Owned Utilities;
• allow local distributed generation to
count in full towards RPS; and
• prioritize the use of the existing
transmission system assets over
building new transmission.
5. Support/encourage transmission, generation,
and demand-reduction projects and solutions
including advocating for financing or funding
6.solutions/options for projects that:
• enhance/ensure reliability;
• ensure equitable cost allocation following
beneficiary pays principles (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 in meeting
operational requirements or flexibility in
meeting State renewable portfolio
standards);
• support the continuation of federal and
state financial incentives that promote
increased renewable development;
• improve market transparency (particularly
transparency of IOU’s transmission and
procurement planning and implementation
activities); and
• reduce negative the environmental
impactsimpact on the Bay Area and the
Local, State, and
Federal
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Goals
Legislative Policy Guidelines
Venue
1. Local
Accountability
2. Reliability 3. GHG
Reduction
4. Cost
Control
Peninsula.
7.6. Advocate for Congressional, legislative, or
administrative actions on matters impacting
costs or operations of the Western Area
Power Administration (Western) such as:
• support of Congressional Field
Hearingshearings to explore modernizing
flood control strategies, river regulation
and generation strategies at Central
Valley Project (CVP) plants to enhance
generation, water delivery, flood control
and fisheries;
• protection of the status of Western Power
Marketing Administration and cost-based
rates;
• provisions for preference customers’ first
take at land available land with economic
potential for wind farms;
• balancing efforts for competing
environmental improvements in rivers and
Delta conditions with water supply and
hydropower impacts;
• support grid modernization without
compromising the primary mission of
Western and recognizing the
achievements already made in California
without adding duplicate costly efforts;
• monitoring and evaluating impacts of
Delta conveyance proposals on Western
Base Resource allocation; and
• advocating for an equitable distribution
of costs between water and power
customers of the Central Valley Project;
and
• advocating for clear product provisions,
fair allocation of Base Resource Capacity
and fair contract terms under Western’s
2025 Power Marketing Plan and new
Western Base Resource contracts.
Federal,
State and
Regional
8.7. Advocate for Congressional 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)
Federal, State
and Regional
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Goals
Legislative Policy Guidelines
Venue
1. Local
Accountability
2. Reliability 3. GHG
Reduction
4. Cost
Control
or the Western Electricity Coordinating
Council (WECC).
9.8. Support fair and reasonable application of
grid reliability requirements established by
NERC, WECC, or FERC and seek appropriate
remedies (if needed) for inequitable or
punitive application of fees and fines.
Federal and
Regional
10.9. Work with CAISO and/or FERC:
• to give buyers of renewable intermittent
resources relief from imbalance penalties;
• to promote financial and operational
changes that result in timely and accurate
settlement and billing; and
• to provide critical input on the need for
various transmission projects in light of the
escalating costs to the City to import power
using the bulk transmission system.
Federal and
State
10. Work with NCPA, CMUA and NERC 10.
Monitor cyber security issues to ensure that:
• Federal, state and regional designations
of “ CPAU, which currently does not have
critical cyber assets” are appropriately
applied to only truly critical local
distribution infrastructure; and
• CPAU, retains local control over
implementation of utility industryits cyber
security needs while remaining exempt from
NERC cyber security standards, policies.
Support NCPA to protect it and procedures.
its member agencies from unnecessary cyber
security regulations.
Federal and
Regional
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FIBER OPTIC
Goals
1. Preserve and enhance the authority of local government to (1) develop broadband solutions that
align with community needs and (2) expand consumer choice for competitive Internet connectivity
and other advanced services delivered over fiber-optic networks.
2. Encourage the competitive delivery of broadband services by permitting the use of public rights-of-
way and Utilities infrastructure in a responsible manner, provided that local rights of way authority
and management is preserved and contractual or otherthe use does not compromise the City’s
existing utility safety, service, and operational sservices obligations.
3. Support local government authority over zoning-related land use for communications infrastructure
in accordance with reasonable and non-discriminatory regulations.
4. Support the Council’s Technology and the Connected City initiative of 2013, to fully leverage the
City’s fiber- optic asset to provide ubiquitous and infrastructure assets such as public rights-of-
way, utility poles and conduit for thereliable ultra-high-speed broadband expansion.connectivity
Goals
Legislative Policy Guidelines
Venue
1. Support
Municipal
Delivery
2. Competitive
Delivery
3. Local
Authority
over Land
Use
4. Support
Council
Initiatives
1. Advocate for these goals through the
American Public Power Association
(APPA), California Municipal Utilities
Association (, CMUA),, National
Association of Telecommunications
Officers and Advisors (NATOA),
National League of Cities (NLC), and the
Next Century Cities initiative (NCC),
with support from City staff.
Federal
and
State
2. Support legislation and regulations that
preserve and enhance municipal
delivery of conventional and advanced
telecommunication services as
prescribed by the Telecommunications
Act of 1996.
Federal
and
State
3. Support the goals of the Federal
Communications Commission’s (FCC),
National Broadband Plan to improve
Internet access nationwide.
Federal
and
State
4. Oppose legislation and regulations that
benefit the incumbent cable TV, and
telephone, and telecommunications
companies at the expense of
community-owned fiber-optic and
wireless networks.
Federal
and
State
5. Support legislation and regulations that Federal
and
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Goals
Legislative Policy Guidelines
Venue
1. Support
Municipal
Delivery
2. Competitive
Delivery
3. Local
Authority
over Land
Use
4. Support
Council
Initiatives
preserve and enhance utility customer
data security and
confidentialityconsumer protections
byrelated to the incumbent providers
of telecommunication services.
State
6. Continue to sSupport the Council’s
municipal fiber and wireless initiatives.
directive to concurrently pursue the
findings and recommendations in the
Fiber-to-the-Premises Master Plan and
Wireless Network Plan and continue
discussions and negotiations with third
parties considering new service
deployments in Palo Alto.
Local
7.6. Support legislation and regulations
that:::
• Permit the contractual use of
public right-of- way and Utilities
infrastructure;
• Preserve local rights-of-way
authority and management;
• Preserve local government zoning
and siting authority for wireless
and wireline communication
facilities;
• Support local “dig once” policies
to deploy infrastructure such as
communications conduit for
future fiber and wireless networks
capable of delivering next-
generation broadband services.
• ensure conduit and fiber are
available for lease on reasonable
terms; and
• Oppose legislation and regulations
that arbitrarily reduce
compensation received by local
governments from other entities
for the economic use of the public
rights-of-way and other public
properties required for that
support communication
infrastructure (e.g., utility poles,
Federal,
State and
Local
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Goals
Legislative Policy Guidelines
Venue
1. Support
Municipal
Delivery
2. Competitive
Delivery
3. Local
Authority
over Land
Use
4. Support
Council
Initiatives
streetlight poles, ducts and
conduits).
NATURAL GAS
Goals
1. Preserve/enhance the ability of municipal utilities to develop and implement their own demand
side efficiency and conservation programs, alternative gas supplies, and rate structuresstructure.
2. 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.
3. Support efforts to reduce greenhouse gas emissions and protect the environment.
4. Preserve just and reasonable utility rates/bills established by local governing bodies.
Goals
Legislative Policy Guidelines Venue 1. Local
Accountability
2. Reliability of
Infrastructure
3. Environment 4. Cost Control
1. Advocate most of these goals
mainly throughLeverage the
American Public Gas Association
(APGA) with minor support from
Palo Alto staffto assist in natural
gas goals .
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 cost effective renewable
gas supplies from in or out of state
sources. In case ofAdvocate for
locally reasonable mandated
renewable portfolio standards,
advocate for controls and off-
ramps similar to the electric RPS
that minimize customer cost
impact.
Federal and
State
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Goals
Legislative Policy Guidelines Venue 1. Local
Accountability
2. Reliability of
Infrastructure
3. Environment 4. Cost Control
4. Advocate for financing or funding
for cost-effective 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
7. Support efforts to improve pipeline
safety.
Federal and
State
8. Work with partners to discourage
extension of CPUC regulatory
authority over municipal gas
operations.
State
10. 9. Oppose legislative
proposals resulting in
unreasonable costs for
Support cap-and-trade market
designs that:
• protect consumers from the
exercise of market power;
• allocate allowances that
mitigate impacts to Palo
AltoAlto’s customers while
preserving City environmental
goals;
• advocate for an allowance
allocation methodology that
provides flexibility for Palo Alto
to structure rates to align GHG
costs and revenues;
• provide flexible compliance
mechanisms such as banking
and borrowing of allowances;
and
• allocate funds generated from cap-
and-trade markets to GHG related
activities, not as a revenue source
for state or federal general funds.
Federal and
State
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Goals
Legislative Policy Guidelines Venue 1. Local
Accountability
2. Reliability of
Infrastructure
3. Environment 4. Cost Control
11. 10. Support legislation that
aims to protect public health and
encourages transparency regarding
the practice of hydraulic fracturing
or “fracking” for natural gas
development, while opposing
blanket moratoriums that aren’t
supported by science.
Federal and
State
Utilities Legislative Policy Guidelines January 2017 Update AAA
Page 16 of 22
WASTEWATER COLLECTION
Goals
1. 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.
2. Encourage efforts to increase the reliability of the local wastewater collection systems.
3. Maintain the provision of reliable and sustainable wastewater collection service at a fair price.
4. Support equal comparisons of wastewater collection systems by regulatory agencies in order to
minimize and reduce onerous, costly, time-intensive reporting requirements and improve value
and accuracy of information reported to the public.
Goals
Legislative Policy Guidelines Venue 1. Local
Accountability
2. Reliable
Infrastructure
3. Maintain
service
4. Valuable
reporting
1. Advocate goals through active
participation in the Association of
Bay Area Governments (ABAG).),
and CMUA.
Local,
Regional
& State
2. Support regulations of wastewater
collection systems that recognize:
• local jurisdictions’ proactive
efforts to replace and maintain
wastewater collections
systems;
• the need to provide affordable
and cost based collection
service; and
• the unique characteristics of
each collection system.
Local,
Regional
& State
3. Support provision of sufficient
resources for regional agencies in
their pursuit ofto enable them to
advocate for:
• environmentally sustainable,
reliable wastewater collection
service at a fair price; and
• regional comparisons of
wastewater collection projects
for future state grant funding.
Local and
Regional
4. Support infrastructure security and
reliability including equitable
allocation of funds for increasing
the security of infrastructure.
Regional,
and State
Utilities Legislative Policy Guidelines January 2017 Update AAA
Page 17 of 22
Goals
Legislative Policy Guidelines Venue 1. Local
Accountability
2. Reliable
Infrastructure
3. Maintain
service
4. Valuable
reporting
5. Advocate for funding and local
regulations for wastewater
collectioncollections system
projects and requirements that
reduce overflows and improve
collection system efficiency.
Regional,
State and
Federal
Utilities Legislative Policy Guidelines January 2017 Update AAA
Page 18 of 22
WATER
Goals
1. Support the ability of publicmunicipal utilities and districts to develop and implementmanage
their own water efficiency and conservation and efficiency programs while retainingand retain
authority over ratemaking, including the ability to optimize volumetric, and fixed, and drought-
related pricing and charges to balance the goals of revenue certainty and water use efficiency.
2. Increase the security and reliability of the regional water system owned and operated by the San
Francisco Public Utilities Commission (SFPUC).
3. Support efficiency and recycled water programs in order to minimize the use of imported supplies.
4. ProvideMaintain the provision of an environmentally sustainable and, reliable suppliessupply of
high quality water. at a fair price.
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
1. Advocate goals through active
participation in the Bay Area Water Supply
and Conservation Agency (BAWSCA),
California Urban Water Conservation
Council (CUWCC),) and California
Municipal Utilities Association (CMUA),,
with support from Palo Alto staff for
BAWSCA
Local,
Regional
and State
2. Participate in 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
Utilities Legislative Policy Guidelines January 2017 Update AAA
Page 19 of 22
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
3.2. Advocate to ensure that legislative actions
regarding the Hetch Hetchy Regional
Water System include:
• timely rebuilding of the regional water
system;
• assurance that the SFPUC is
adequately assessing and
mitigating risks of infrastructure
failure;
• maintenance of the quality of
delivered water;
• minimization of any increase in the
cost of water;
• no additional exposure to more
frequent or severe water
shortages;
• increased real-time monitoring
data availability to ensure water
quality;
• support for the existing water system
and its operation;
• SWRCB responsiveness to SFPUC water
quality issues;.
Local,
Regional
and State
3. 4. Advocate for interpretations or
implementation of Water Code provisions
that maintain or reinforce the authorities
and protections available to the City and
BAWSCA members outside of San
Francisco.
Local,
Regional
and State
Utilities Legislative Policy Guidelines January 2017 Update AAA
Page 20 of 22
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
5. 4. Support BAWSCA in efforts to enable
it to advocate forachieve:
• an environmentally sustainable,
reliable supply of high quality water at
a fair price;
• for Wholesale Customers’ rights
under the Water Supply Agreement
for water from SFPUC that meets
quality standards;
• a SFPUC rate structure that is
consistent with the Water Supply
Agreement and is based on water
usage;
• a contract amendment to modify the
drought time water allocation
between the SFPUC and the BAWSCA
agencies;
• preservation of Palo Alto’s existing
contractual water allocation and
transportation rights on the SFPUC
Hetch Hetchy system; and
• regional planning for conservation,
recycled water, and other water supply
projects.
Local and
Regional
6. 5. Advocate for actions that:
• preserve Palo Alto’s existing
contractual rights; and
• preserve local control over water
use; and
• limit encroachment from outside
jurisdictions.
Local and
Regional
67. 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
78. Support notification requirements that
inform residents/customers but do not
inflict undue or unobtainable requirements
on the utility.
State
89. Support local control of public benefit
funds, funding levels and program
design.
State
Utilities Legislative Policy Guidelines January 2017 Update AAA
Page 21 of 22
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
910. Support beneficiary pays methodologies
to prevent taxes or fees imposed on
SFPUC customers to fund infrastructure
improvements and costs of water sources
that do not serve Palo Alto customers.
State and
Regional
101. Advocate for financing or, funding, and,
where applicable, tax exemption, for water
conservation programs, water rebate
programs, and recycled water projects that
meet end-use needs and conserve potable
water and; oppose legislation that would
reduce such funding.
State,
Regional
and
Federal
11.12. Support infrastructure security and
reliability that includes equitable
allocation of funds for increasing the
security of infrastructure and that
protects the City from unnecessary
regulations. Support legislation that
promotes responsible groundwater
management.
Local,
State and
Federal
123. Support legislation that promotes
responsible groundwater management
while recognizing Palo Alto’s existing and
historical groundwater extraction
practices. Support Proposition 218
reform efforts to provide ratemaking
flexibility to balance conservation,
revenue sustainability, and low income
programs.
State
134. Support Proposition 218 reform efforts
to provide ratemaking flexibility to
balance conservation, revenue
sustainability, and low income assistance
programs.Advocate for water
conservation policies (both drought
response and long term) that achieve
water sustainability while minimizing
customer and commercial impact,
protecting the City’s urban canopy and
minimizing the City’s enforcement costs.
Local and
State
Utilities Legislative Policy Guidelines January 2017 Update AAA
Page 22 of 22
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
145. Advocate for reasonable statewide
water conservation efforts (both drought
response and long term) that achieve
required water savings while minimizing
customer and commercial impact,
protecting the City’s urban canopy and
minimizing the City’s enforcement
costs.Protect SFPUC’s water rights.
Local and
State
156. ProtectSupport legislation that would
protect the CityCity’s infrastructure and
County of San Francisco’streatment
investments from future state-wide cuts
in water rights as well as those of the co-
grantees of the Raker Actuse.
State
167. Support legislationOppose government
action that would protectcreates undue
burdens on or unreasonably expands the
City’s infrastructurerole and treatment
investments from future state-wide cuts
inresponsibility of water use.suppliers
State
EXCERPTED DRAFT MINUTES OF THE JANUARY 11, 2017 SPECIAL MEETING
UTILITIES ADVISORY COMMISSION
ITEM 1: ACTION: Staff Recommendation that the Utilities Advisory Commission Recommend
that the City Council Adopt a Resolution Approving the Updated City of Palo Alto Utilities
Legislative Policy Guidelines
Acting Assistant Director of Engineering Debbie Lloyd said staff comes to the UAC annually to
update the legislative guidelines. These guidelines are used when staff meets with legislators.
The attachment to the report shows the redline changes.
Commissioner Trumbull asked if the guidelines covered regulatory items as well as legislative;
Lloyd responded that they did.
Senior Resource Planner Heather Dauler said staff also coordinated with the City’s guidelines as
well. There were no changes to the goals for all utilities. The first recommendation was to
provide policy guidance enabling staff to engage with key accounts when legislation comes up
that would affect them. The next recommendations were to strike redundant language related
to ratemaking, customer data security infrastructure, and cap and trade. The changes for the
electric utility included modifications to language related to Net Energy Metering (NEM)
successor programs to reflect the fact the City has already adopted a successor program. The
only change for the gas utility was to modify redundant language related to the cap and trade
program. The only change for the wastewater collection utility was to add a basic guideline
related to infrastructure security.
Commissioner Schwartz asked why infrastructure security wasn’t applicable to all utilities, not
just wastewater; Dauler said staff could consider that.
Dauler discussed the changes recommended for the water utility guidelines. The guideline
related to the CUWCC BMPs was recommended to be deleted because it was not currently
applicable. Staff also recommended adding language related to SFPUC. Staff also recommended
streamlining language related to Proposition 218. This was also in preparation for dealing with
new upcoming State conservation plans.
Schwartz said policies were changing at the Federal level, with California trying to maintain its
leadership role. Was there any specific language needed to give staff the ability to respond to
those issues?
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Dauler believed existing language was sufficient.
Lloyd said it was also possible to return to the UAC and Council if a change was needed. She
agreed with Dauler that the existing language gave staff adequate flexibility.
Commissioner Johnston asked whether the guidelines were in priority order.
Lloyd said there was no priority order in the guidelines. The guidelines were meant to achieve
the three to four high level goals for each section.
Utilities General Manager Shikada said the legislative guidelines were often effectively
defensive, particularly to deal with “gut and amend” bills at the end of the legislative section.
He addressed Commissioner Schwartz’s point about Federal action, saying he expected there to
be lead time to respond to those issues.
Danaher asked whether the guidelines addressed energy efficiency; Dauler said they did.
Dauler discussed potential issues that were going to arise in 2017. She said that regionalization
was potentially going to be delayed.
Lloyd said anticipated changes to environmental policy under the Trump administration could
affect the appetite for other states to join California in a regional energy market. The City would
be involved in upcoming discussions related to these issues through the BAMX group.
Dauler discussed Western issues. There was some hope that progress would be made on the
Central Valley Project Improvement Act (CVPIA).
Chair Cook asked staff to state for the record why we were interested in Western issues.
Dauler said the Western Area Power Administration provided a large fraction of the City’s
power. The CVPIA was passed a long time ago to address environmental impacts of the CVP,
but there was some concern that the costs passed to power customers were too high.
Lloyd said staff was beginning working with Western on the next contract period ten years from
now.
Schwartz asked whether regionalization could affect the carbon content of the power we buy
Lloyd said regionalization could affect the carbon content of market power.
Shikada said staff expected major changes to these issues due to the Trump administration.
Dauler said changes to Federal policies were expected due to the 2016 presidential election and
the new appointees of the new administration. California was preparing to fight anticipated
actions. In 2016 water was a major issue due to drought. Currently the legislature was waiting
to see whether precipitation would obviate the need for a drought bill. There was also an
energy bill in 2016 that contained provisions that would help with dam relicensing, but it died.
The bill sponsor was interested in it, but it was not clear whether there would be appetite in the
House to move it forward.
Public speaker Jeff Hoel spoke regarding Fiber. He noted there was no discussion of Fiber Utility
issues in the staff presentation. He said there were differences between the redlined and final
draft. He noted there was no discussion of Dig Once. He asked whether the policy change
would take effect prior to Council action.
Dauler said there were no substantive changes to Fiber policies proposed. The Dig Once policy
language remained unchanged.
Commissioner Trumbull verified that no changes to policy would occur until Council acted.
Shikada noted there were unintentional differences between the redline and final drafts in that
the proposed Dig Once language changes shown in the redline had not been made in the final
version.
Dauler said it was the intention to keep Dig Once language in the policy. She would follow up to
fix the issue with Fiber guideline six.
ACTION: Commissioner Trumbull moved, seconded by Commissioner Danaher to recommend
approval of the guidelines with the correction of the Dig Once language. The motion carried
unanimously (6-0, with Chair Cook, Vice Chair Danaher, Commissioners Forssell, Johnston,
Schwartz, and Trumbull voting yes and Commissioner Ballantine absent).