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RPS Compliance and Enforcement Presentation to the: FPSC Staff Workshop on a Renewable Portfolio Standard September 27,

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. RPS Compliance. Verification methodologies: 1) Contract path

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RPS Compliance and Enforcement Presentation to the: FPSC Staff Workshop on a Renewable Portfolio Standard September 27,

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  1. 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. RPS Compliance • 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?

  4. RPS Compliance • 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

  5. RPS Enforcement 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?

  6. RPS Enforcement 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

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