RPS Compliance and Enforcement Presentation to the: FPSC Staff Workshop on a Renewable Portfolio Standard September 27, 2007 Judy Harlow Division of Economic Regulation Florida Public Service Commission

2 RPS Compliance Verification methodologies: 1) Contract path 2) Renewable Energy Credits (RECs) 3) Utility ownership of renewable facility Once a verification methodology is chosen, how do we make it work?

3 Common Issues: Who administers verification of compliance? - state agency or third party Should there be a weighting system based on objectives? - multipliers or tiered approach Should there be a safety valve, such as an alternative compliance payment? - who administers - use of funds - recovery for IOUs Should self-service generation be counted toward goals? RPS Compliance

4 Issues that are specific to RECs: Should out-of-state RECs be counted? - regional limitation - requirement that energy be delivered to Florida - coordination to prevent double counting What flexibility measures should be allowed? - banking - borrowing - true-up period RPS Compliance

5 How often should utilities be reviewed? - annual or other interim goals What is the best way to ensure compliance? - penalties versus guidelines Penalty-specific issues: - How should penalties be applied? - How should funds be used? - Who administers the funds? - Force majeure exceptions? - Should IOUs receive recovery? RPS Enforcement

6 Should we establish a baseline of current renewables? - If so, what counts toward baseline? What reporting requirements are needed? Should there be a process to review the RPS? - automatic process such as conservation goals proceedings (review every 5 years) - ongoing review with no automatic process RPS Enforcement