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HomeMy WebLinkAboutStaff Report 3637 City of Palo Alto (ID # 3637) City Council Staff Report Report Type: Informational Report Meeting Date: 4/8/2013 City of Palo Alto Page 1 Summary Title: 4th Semi-Annual LEAP Update Title: Fourth Semi-Annual Long-term Electric Acquisition Plan (LEAP) Update From: City Manager Lead Department: Utilities This fourth and final semi-annual update of the Long-term Electric Acquisition Plan (LEAP) is provided as information only. The purpose of the update is to keep the City Council apprised of staff’s efforts towards implementing the Council-approved LEAP Objectives, Strategies and Implementation Plan (Attachment B). Executive Summary Since the last LEAP update in September 2012, significant progress has been made towards several key LEAP implementation items including: Council approval of the Carbon Neutral Plan in March 2013; Council approval of the Brannon Solar power purchase agreement, bringing the City’s Renewable Portfolio Standard in 2015 from 29.7% to 34.5% within the 0.50 cent/kWh rate cap; evaluation of new long-term renewable energy proposals submitted in response to the Fall 2012 RFP; Council authorization to execute Electric Master Agreements with nine new electric suppliers in March 2013; and initiation of the process to revamp the PaloAltoGreen program. Since the LEAP Implementation Plan was approved in March 2011, 34 of the original 38 tasks have been completed, are in process, or are ongoing. The remaining four projects are on hold or delayed, but will be completed. Therefore, staff will no longer provide updates related to the implementation of the LEAP Implementation Plan. LEAP will be reviewed in the context of the recently approved Carbon Neutral Plan and staff may recommend modifications to Council as needed to effectively implement both plans. Attachments:  Attachment A: LEAP Update March 2013 (PDF)  Attachment B: LEAP April 2012 (PDF) Attachment A Page 1 of 8 Long-term Electric Acquisition Plan (LEAP) Semi-annual Update -- April 2013 LEAP Implementation Plan Item Estimated Completion in LEAP April 2013 Update Status Strategy #1 - Resource Acquisition 1. Adjust planning and portfolio models to include an integrated and least cost planning perspective which evaluates demand and supply side resources in an integrated manner and includes time of delivery, locational and environmental costs and benefits. Dec. 2010 Completed 2. Evaluate the impacts of energy efficiency, demand reductions and electric vehicle penetration in Palo Alto in the annual development of the electric load forecast. Dec. 2010 Completed Strategy #2 – Electric Energy Efficiency and Demand Reduction 3. Provide quarterly updates on electric efficiency program achievements including tracking against 10-Year Energy Efficiency goals to the UAC and annual updates to the City Council. quarterly No update* On-going 4. Develop Energy Efficiency Implementation Plan for the 2010 10-Year Electric EE Plan addressing certain items identified in the May 2010 Council Colleagues Memo and identification of resources and funding needed to achieve EE goals. Apr. 2011 Completed 5. Evaluate fuel switching energy efficiency measures and include them, if cost-effective, in the Electric and Gas EE Implementation Plans. Feb. 2011 Completed 6. Develop a pilot Demand Response Program for large commercial industrial customers for implementation in summer 2011. Apr. 2011 Completed Attachment A Page 2 of 8 LEAP Implementation Plan Item Estimated Completion in LEAP April 2013 Update Status 7. Assess the feasibility and cost-effectiveness of using current and potential thermal energy storage (TES) systems to shift load from on-peak periods to off-peak periods, for use in a demand response program, or for meeting any energy storage needs. Coordinate with task 21 to develop targets, if appropriate. Dec. 2011 In the summer of 2012, an intern helped analyze the applicability of storage systems within Palo Alto and found no compelling business case to do so. A more detailed distribution feeder based analysis is expected to be undertaken during the summer of 2013, and both findings are expected to be discussed with the UAC by November 2013. Report to UAC by Nov 2013 8. Fully integrate the effects on energy efficiency in the long-term electric load forecast. Nov. 2010 Completed Strategy #3 – Renewable Portfolio Standard (RPS) 9. Evaluate the merits of implementing a feed-in-tariff (FIT) and the potential to meet RPS goals through local renewable resources. Jan. 2011 Completed 10. Seek UAC recommendation and Council approval of the policy elements of a FIT to encourage local renewable resource projects. May 2011 Completed 11. Continue working with NCPA to identify opportunities, including joint-ownership, for developing qualifying renewable resources. On-going Joint ownership options being investigated include a geothermal project (see item #13) and the installation of micro-turbines at the Calaveras Hydroelectric Project. On-going 12. Evaluate the use of renewable energy credits (RECs) to meet a portion of the City’s RPS goal and/or greenhouse gas emission reduction goals and monitor the regulations and requirements regarding the use of RECs to meet RPS goals. On-going On March 4, 2013, Council approved the Carbon Neutral Plan, which allows the use of RECs to neutralize GHG associated with market purchases. Completed Attachment A Page 3 of 8 LEAP Implementation Plan Item Estimated Completion in LEAP April 2013 Update Status 13. Evaluate a proposed geothermal project being considered by NCPA, including a pre-pay option and the benefit, costs, and risks of a pre-pay structure. June 2011 This project has been delayed due to development issues. Staff and NCPA are monitoring key contract milestones and will make an assessment whether or not to terminate the PPA with Western Geo. In process 14. Conduct a Request for Proposals for eligible renewable resources including RECs and evaluate alternative renewable resource technologies and contracting mechanisms. RFP in June 2011 Staff issued a Request for Proposals for eligible renewable resources in September 2011. A total of 65 project proposals were submitted. Staff negotiated a Power Purchase Agreement (PPA) for the 20 MW Brannon Solar project with the finalist, Trina Solar. Council approved this agreement in November 2012. Staff issued another RFP for eligible renewable resources in August 2012. A total of 92 project proposals were received in September 2012. Staff is now finalizing negotiations on three PPAs for solar projects with the finalists in this process and anticipates bringing these agreements to Council for consideration by June 2013. In process Strategy #4 – Local Generation 15. Provide an update of past local generation feasibility studies and actions to UAC and Council Dec. 2010 Completed Attachment A Page 4 of 8 LEAP Implementation Plan Item Estimated Completion in LEAP April 2013 Update Status 16. Assess the potential for and feasibility of small local distributed and non-distributed, renewable and cogeneration projects, including using a FIT to encourage these projects. Jan. 2011 Renewable projects are being evaluated as part of the City’s FIT program (see item #19). An assessment of cogeneration will be part of evaluation of the City’s PLUG-In program. See item #18. In process 17. Assess the potential, benefits and costs of developing and/or joint ownership of a 25 to 50 MW gas-fired power plant located in or near Palo Alto to meet load, reliability and local capacity needs. Jun. 2011 Completed 18. Evaluate the City’s PLUG-In Program to encourage cogeneration including rules, regulations, and buy back rates and recommend modifications as needed. December 2011 Staff proposal is being developed. In process 19. Following receiving Council direction from Implementation Plan Initiative #10, develop a FIT proposal including rate, rules, regulations, standard contract form and limits. To be deter- mined Completed 20. Assess the economics and potential of the anaerobic digester as a local generation resource for CPAU Sep. 2011 In January 2013 Council approved an energy purchase policy for waste to energy projects in Palo Alto. Further evaluation will be performed by the Public Works Department with the Utilities Department advising as necessary. Completed Attachment A Page 5 of 8 LEAP Implementation Plan Item Estimated Completion in LEAP April 2013 Update Status 21. Assess the need for and value of energy storage to support local renewable distributed generation resources. Determine any appropriate energy storage targets to be achieved by December 31, 2016, and December 31, 2021. Report back to the Council regarding what procurement targets, if any, are deemed to be appropriate so that the Council may adopt such procurement targets, if determined to be appropriate, by October 1, 2014. Oct. 2014 As directed by Public Utilities Code Section 2836, staff will bring to UAC/Council a report with recommended energy storage targets, if any, for potential council adoption in Winter of 2013. See task #7 in support of this task. November 2013 Strategy #5 – Climate Protection 22. Promote the City’s Plug-in program to encourage development of cogeneration systems. On-going Staff continues to provide information to interested applicants under the City’s existing PLUG-In program. Also see item #18 above. On-going 23. Analyze electric vehicle (EV) charging patterns and evaluate rates to incent nighttime EV charging. Jun. 2011 Council adopted a TOU rate for the CustomerConnect pilot program on December 10, 2012. Up to 100 customers with EVs will be allowed to participate in the pilot program. Planned for Fall of 2012 to Fall of 2013 24. Meet AB32 mandated annual reporting requirements to California Air Resources Board on annual volumes of electricity purchases by resource. Annually, next in Jun. 2013 Completed 25. Track and report annually on 6 major greenhouse gas emissions (CO2, CH4, N2O, SF6, HFCs, PFCs) for all of the City’s municipal operations and calculate electric portfolio’s overall emissions coefficients (lbs of CO2, CH4, and N2O per MWh of purchases). Annually, next in Sep. 2012 Report with emissions data for calendar year 2010 submitted to The Climate Registry in December 2011. Utilities and Public Works staff is coordinating efforts to submit calendar year 2011 and 2012 reports to The Climate Registry by April 2013. On-going Attachment A Page 6 of 8 LEAP Implementation Plan Item Estimated Completion in LEAP April 2013 Update Status 26. Evaluate the costs, benefits and impacts of the implementation of an electric portfolio carbon neutral policy and the setting of quantitative goals (e.g. carbon intensity, total GHG emissions). Jan. 2012 Council approved carbon neutral definition in November 2012 and the Carbon Neutral Plan in March 2013. Completed 27. Evaluate PaloAltoGreen program design and recommend modifications, as appropriate, including constructing PaloAltoGreen to assist in meeting Renewable Portfolio Standard goals. Jun. 2012 The UAC discussed potential PaloAltoGreen redesign options in December 2012, and the Council held a study session on potential redesign options in February 2013. Recommendations are expected to be provided to the UAC in April, Finance Committee in May and Council in June of 2013. In process Strategy #6 – Hydro Resource Management 28. Evaluate potential rate adjustment mechanisms that would adjust electric rates based on hydrologic year type and develop a recommendation for a rate. Apr. 2011 Implementation has been delayed pending development of new rate policies and reserves policies, which are expected to be completed in FY 2014. On hold 29. Assess the value related to Palo Alto’s participation in the CAISO’s Metered Subsystem Agreement and the use of the Calaveras hydroelectric project for load following. On-going No update * On-going 30. Identify long-term opportunities to maximize the value of the Calaveras hydroelectric project as an energy storage resource. On-going Staff is working with NCPA to understand new flexible ramping requirements to be proposed CAISO capacity needs for intermittent resources and the role Calaveras will play. Additionally, staff intends to explore hydro energy storage in the context of meeting the requirements set forth in AB 2514 (see item #21). On-going Attachment A Page 7 of 8 LEAP Implementation Plan Item Estimated Completion in LEAP April 2013 Update Status 31. Work with NCPA to seek opportunities to increase the efficiency of the Calaveras hydroelectric project and implement operational value maximizing strategies. On-going No update * On-going Strategy #7 – Market Price Exposure Management 32. Evaluate a block purchase of up to 25 MW to meet base load needs for Jan-Mar and Nov-Dec for a term of up to 5 years. Feb. 2011 No Update * On hold 33. Conduct an RFP for new electric master agreement counterparties. Dec. 2011 In March 2013, Council authorized the City Manager to finalize and execute nine electric master agreements and carryout transactions under the agreements. Completed 34. Explore opportunities with NCPA, other municipal utilities and/or third party suppliers to reduce scheduling and/or operating costs. On-going No update * On-going 35. Continue to implement a 3-year laddering strategy to manage market price uncertainty. On-going No update * On-going Strategy #8 – Transmission and Reliability 36. Investigate transmission connection voltage upgrade from 115 to 230 kV, and the potential for a transmission reliability connection to west side. On-going CPAU and Stanford are working on a memorandum of understanding and a firm proposal for SLAC and the Department of Energy (DOE). Currently CPAU’s consultant is rerunning the load flow studies to incorporate new load assumptions for SLAC and Stanford. CPAU and Stanford are also moving forward on right-of-way, land use, and routing options. On-going 37. Explore transmission opportunities and strategies to meet long-term renewable portfolio objectives beyond 2020. On-going No Update * On-going Attachment A Page 8 of 8 LEAP Implementation Plan Item Estimated Completion in LEAP April 2013 Update Status 38. Evaluate joint efforts for power plant ownership opportunities or long-term agreements to meet the City’s Resource Adequacy Program requirements. On-going No Update * On-going * No update – For these items, there is no update since the September 2012 semi-annual LEAP update Key for Acronyms: AB – Assembly Bill AB32 – Assembly Bill for Greenhouse Gas Emissions Reduction AB 2514 – Assembly Bill for Energy Storage CAISO – California Independent System Operator CARB – California Air Resources Board CH4 – Methane CO2 – Carbon Dioxide CPAU – City of Palo Alto Utilities DOE – Department of Energy EE – Energy Efficiency EV – Electric Vehicle FIT – Feed-in-tariff GHG – Greenhouse Gas Emissions HFCs – Hydrofluorocarbons kV – Kilo volt kWh – Kilowatt-hour MSSA – Metered Subsystem Agreement MW – Mega Watt MWh – Mega Watt hour N2O – Nitrous Oxide NCPA – Northern California Power Agency PFCs – Perfluorocarbons PLUG-In – Power from Local Ultra-clean Generation Incentive PPA – Power Purchase Agreement RFP – Request for Proposal RPS – Renewable Portfolio Standard SB2 1X – California Senate Bill for 33% RPS SF6 – Sulfur Hexafluoride SLAC – SLAC National Accelerator Laboratory TES – Thermal Energy Storage TOU – Time-of-Use UAC – Utilities Advisory Commission WAPA – Western Area Power Administration 1 Attachment B Long-term Electric Acquisition Plan (LEAP) Objectives, Strategies and Implementation Plan Approved March 7, 2011 (Resolution No. 9152) Modified by Council March 19, 2012 (Staff Report No. 2581) Modified by Council April 16, 2012 (Staff Report No. 2710) LEAP Objectives: 1. Meet customer electricity needs through the acquisition of least total cost energy and demand resources including an assessment of the environmental costs and benefits 2. Manage supply portfolio cost uncertainty to meet rate and reserve objectives. 3. Enhance supply reliability to meet City and customer needs by pursuing opportunities including transmission system upgrades and local generation. LEAP Strategies and Implementation Plan Steps: 1. Resource Acquisition – Pursue the least total cost resources including an assessment of environmental costs and benefits to meet the City’s needs in the long term by: a. Evaluating each potential resource on an equal basis by evaluating rate impacts and establishing costs and values for location, time of day and year, carbon, value of renewable supplies and any secondary benefits attributed to the resource; and b. Including all resources – conventional energy, local and remote renewable energy supplies, energy efficiency, cogeneration, and demand reduction – in the evaluation. Implementation Plan Items for Strategy #1 – Resource Acquisition Estimated Completion 1. Adjust planning and portfolio models to include an integrated and least cost planning perspective which evaluates demand and supply side resources in an integrated manner and includes time of delivery, locational and environmental costs and benefits. Dec. 2010 2. Evaluate the impacts of energy efficiency, demand reductions and electric vehicle penetration in Palo Alto in the annual development of the electric load forecast. Dec. 2010 2. Electric Energy Efficiency and Demand Reduction – Fund programs that maximize the deployment of cost-effective, reliable and feasible energy efficiency and demand reduction opportunities as the highest priority resources by: a. Every three years, preparing a ten-year energy efficiency plan that identifies all cost- effective energy efficiency opportunities; 2 b. Using the cost of long-term renewable energy resources adjusted for time of day factors and location as the avoided cost when evaluating cost effectiveness of energy efficiency measures; c. Designing and making energy efficiency programs available to all customers; and d. Considering the impacts (costs, benefits and GHG emissions) of substituting electricity-using appliances for natural gas-using appliances and vice versa in the ten- year energy efficiency plan. Implementation Plan Items for Strategy #2 – Electric Energy Efficiency and Demand Reduction Estimated Completion 3. Provide quarterly updates on electric efficiency program achievements including tracking against 10-Year Energy Efficiency goals to the UAC and annual updates to the City Council. quarterly 4. Develop Energy Efficiency Implementation Plan for the 2010 10-Year Electric EE Plan addressing certain items identified in the May 2010 Council Colleagues Memo and identification of resources and funding needed to achieve EE goals. Apr. 2011 5. Evaluate fuel switching energy efficiency measures and include them, if cost- effective, in the Electric and Gas EE Implementation Plans. Feb. 2011 6. Develop a pilot Demand Response Program for large commercial industrial customers for implementation in summer 2011. Apr. 2011 7. Assess the feasibility and cost-effectiveness of using current and potential thermal energy storage (TES) systems to shift load from on-peak periods to off-peak periods, for use in a demand response program, or for meeting any energy storage needs. Coordinate with task 21 to develop targets, if appropriate. Sep. 2011 3. Renewable Portfolio Standard (RPS) – Reduce the carbon intensity of the electric portfolio by acquiring renewable energy supplies by: a. Pursuing a minimum level of renewable purchases of at least 33% of retail sales by 2015 with the following attributes: i. The contracts for investment in renewable resources shall not exceed 30 years in term. ii. Pursue only renewable resources deemed to be eligible by the California Energy Commission (CEC). iii. Evaluate use of Renewable Energy Certificates (RECs) to meet RPS. b. Ensuring that the retail rate impact for renewable purchases does not exceed 0.5 ¢/kWh on average; and c. Performing an ongoing evaluation of the Palo Alto Clean Local Energy Accessible Now (CLEAN) program. 3 Proposed Implementation Plan Items for Strategy #3 – Renewable Portfolio Standard (RPS) Estimated Completion 8. Fully integrate the effects on energy efficiency in the long-term electric load forecast. Nov. 2010 9. Evaluate the merits of implementing a feed-in-tariff (FIT) and the potential to meet RPS goals through local renewable resources. Jan. 2011 10. Seek UAC recommendation and Council approval of the policy elements of a FIT to encourage local renewable resource projects. May 2011 11. Continue working with NCPA to identify opportunities, including joint- ownership, for developing qualifying renewable resources. On-going 12. Evaluate the use of renewable energy credits (REC) to meet a portion of the City’s RPS goal and/or greenhouse gas emission reduction goals and monitor the regulations and requirements regarding the use of RECs to meet RPS goals. On-going 13. Evaluate a proposed geothermal project being considered by NCPA, including a pre-pay option and the benefit, costs, and risks of a pre-pay structure. June 2011 14. Conduct a Request for Proposal for eligible renewable resources including RECs and evaluate alternative renewable resource technologies and contracting mechanisms. RFP in June 2011 4. Local Generation – Promote and facilitate the deployment of cost-effective local resources by: a. Using the renewable market price referent (MPR) adjusted for time of day factors and location as the avoided cost when evaluating cost effectiveness of local resources; b. Considering energy delivery cost uncertainty and strategic value options when evaluating opportunities; c. Evaluating a Feed-in-Tariff to promote locally sited renewable resources; d. Evaluating cost-effective energy storage resources; and e. Evaluating the feasibility of developing a 25 to 50 MW generating facility connect to the City’s distribution system. Proposed Implementation Plan Items for Strategy #4 – Local Generation Estimated Completion 15. Provide an update of past local generation feasibility studies and actions to UAC and Council Dec. 2010 16. Assess the potential for and feasibility of small local distributed and non- distributed, renewable and cogeneration projects, including using a FIT to encourage these projects. Jan. 2011 17. Assess the potential, benefits and costs of developing and/or joint ownership of a 25 to 50 MW gas-fired power plant located in or near Palo Alto to meet load, reliability and local capacity needs. Jun. 2011 4 Proposed Implementation Plan Items for Strategy #4 – Local Generation Estimated Completion 18. Evaluate the City’s PLUG-In Program to encourage cogeneration including rules, regulations, and buy back rates and recommend modifications as needed. Dec. 2011 19. Following receiving Council direction from Implementation Plan Initiative #10, develop a FIT proposal including rate, rules, regulations, standard contract form and limits. To be determined 20. Assess the economics and potential of the anaerobic digester as a local generation resource for CPAU Sep. 2011 21. Assess the need for and value of energy storage to support local renewable distributed generation resources. Determine any appropriate energy storage targets to be achieved by December 31, 2016, and December 31, 2021. Report back to the Council regarding what procurement targets, if any, are deemed to be appropriate so that the Council may adopt such procurement targets, if determined to be appropriate, by October 1, 2014. Jun. 2012 5. Climate Protection – Reduce the electric portfolio’s carbon intensity by: a. Supporting the City municipal government’s climate protection goals; b. Promoting the use of technologies (e.g. incentives for cogeneration systems, promotion of EVs, in-home energy displays) and programs that will reduce the community’s carbon footprint at a cost of up to the City’s value of carbon; c. Continuing to offer a renewable resource-based retail rate for all customers who want to voluntarily select an increased content of non-hydro renewable energy; and. d. Evaluating quantitative goals for possible future implementation. Proposed Implementation Plan Items for Strategy #5 – Climate Protection Estimated Completion 22. Promote the City’s Plug-in program to encourage development of cogeneration systems. On-going 23. Analyze electric vehicle (EV) charging patterns and evaluate rates to incent nighttime EV charging. Jun. 2011 24. Meet AB32 mandated annual reporting requirements to California Air Resources Board on annual volumes of electricity purchases by resource. Annually, next in Jun. 2011 25. Track and report annually on 6 major greenhouse gas emissions (CO2, CH4, N2O, SF6, HFCs, PFCs) for all of the City’s municipal operations and calculate electric portfolio’s overall emissions coefficients (lbs of CO2, CH4, and N2O per MWh of purchases). Annually, next in Sep. 2011 26. Evaluate the costs, benefits and impacts of the implementation of an electric portfolio carbon neutral policy and the setting of quantitative goals (e.g. carbon intensity, total GHG emissions). Jan. 2012 5 Proposed Implementation Plan Items for Strategy #5 – Climate Protection Estimated Completion 27. Evaluate PaloAltoGreen program design and recommend modifications, as appropriate, including constructing PaloAltoGreen to assist in meeting Renewable Portfolio Standard goals. Jun. 2012 6. Hydro Resource Management – Actively monitor and manage cost uncertainty related to variations in hydroelectric supply and maximize value of hydro resources by: a. Planning for an average hydro year on a long-term basis; b. Utilizing cost effective hydro resource management products; and c. Implementing opportunities to maximize benefits and reduce costs of the Western Base Resource and Calaveras hydroelectric resources. Proposed Implementation Plan Items for Strategy #6 – Hydro Resource Management Estimated Completion 28. Evaluate potential rate adjustment mechanisms that would adjust electric rates based on hydrologic year type and develop a recommendation for a rate. Apr. 2011 29. Assess the value related to Palo Alto’s participation in the CAISO’s Metered Subsystem Agreement and the use of the Calaveras hydroelectric project for load following. On-going 30. Identify long-term opportunities to maximize the value of the Calaveras hydroelectric project as an energy storage resource. On-going 31. Work with NCPA to seek opportunities to increase the efficiency of the Calaveras hydroelectric project and implement operational value maximizing strategies. On-going 7. Market Price Exposure Management – Actively monitor and manage operational, counterparty and wholesale energy price risk in the short-term (up to three to five years) by: a. Maintaining an adequate pool of creditworthy suppliers; and b. Diversifying supply purchases across commitment date, start date, duration, suppliers and pricing terms in alignment with rate stability objectives and reserve guideline. Proposed Implementation Plan Items for Strategy #7 – Market Price Exposure Management Estimated Completion 32. Evaluate a block purchase of up to 25 MW to meet base load needs for Jan- Mar and Nov-Dec for a term of up to 5 years. Feb. 2011 33. Conduct an RFP for new electric master agreement counterparties. Dec. 2011 34. Explore opportunities with NCPA, other municipal utilities and/or third party suppliers to reduce scheduling and/or operating costs. On-going 35. Continue to implement a 3-year laddering strategy to manage market price uncertainty. On-going 6 8. Transmission and Reliability – Pursue the reliability of supply at fair and reasonable transmission and delivery costs by: a. Actively participating through collaborative efforts with other entities, in local, regional, statewide and federal regulatory and legislative forums; b. Participating in transmission and reliability market design forums to ensure that adopted market designs result in adequate reliability, workably competitive markets and equitable cost allocation; c. Evaluating interconnection options to the City to increase service reliability and lower delivery costs; and d. Exploring transmission opportunities and strategies to meet long-term renewable portfolio objectives beyond 2020. Proposed Implementation Plan Items for Strategy #8 – Transmission and Reliability Estimated Completion 36. Investigate transmission connection voltage upgrade from 115 to 230 kV, and the potential for a transmission reliability connection to west side. On-going 37. Explore transmission opportunities and strategies to meet long-term renewable portfolio objectives beyond 2020. On-going 38. Evaluate joint efforts for power plant ownership opportunities or long-term agreements to meet the City’s Resource Adequacy Program requirements. On-going