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'eV A I= IL h V L I L Y I. l F F <br />lag <br />PUBLIC UTILITIES <br />BOARD OF PUBLIC UTILITIES <br />RIVERSIDE PUBLIC UTILITIES <br />Board Memorandum <br />DATE: JUNE 19, 2015 <br />ITEM NO: 6 <br />SUBJECT: ANNUAL ELECTRICAL DISTRIBUTION UTILITY USE OF ALLOWANCE VALUE <br />REPORT TO THE CALIFORNIA AIR RESOURCES BOARD, AND ATTESTATION <br />ISSUE: <br />The issue for Board of Public Utilities (Board) consideration is approval of, and attestation as to the <br />accuracy of, the City's 2014 use of allowance value associated with its allocation of Greenhouse Gas <br />Allowances (GHG) from the California Air Resources Board (CARB). <br />RECOMMENDATIONS: <br />That the Board of Public Utilities: <br />1. Approve the Electrical Distribution Utility (EDU) Use of Allowance Form; <br />2. Attest as to the accuracy of the EDU Use of Allowance Form; and <br />3. Authorize the City Manager or his designee to execute and submit the attestation. <br />BACKGROUND: <br />Enacted in 2006, Assembly Bill (AB) 32 mandated CARB to develop regulations to limit California's GHG <br />emissions to 1990 levels by the year 2020. In December 2011 CARB developed its framework, <br />associated regulations and market mechanisms to implement AB 32, to become effective on January 1, <br />2012. The cornerstone of CARB's GHG regulations is its Cap and Trade (C &T) Program for GHG <br />allowances. EDUs that emit GHGs (such as fossil fuels associated with generating electricity) have an <br />annual compliance obligation, and must possess sufficient "permits" (e.g., GHG allowances) to offset <br />such GHG emissions. <br />To mitigate an EDU's retail electric rate impacts from the mandatory C &T Program, the implementing <br />regulations provided EDUs with a "free" allocation of GHG allowances through calendar year (CY) 2020. <br />Such "freely" allocated GHG allowances can be used to directly offset a Publicly Owned Utilities' GHG <br />compliance obligation. The C &T regulations contain strict limitations governing the use of the value and <br />the proceeds derived from the sale of such directly (e.g., "freely ") allocated allowances, including <br />limitations imposed by the Utilities' governing body. Such limitations are found in Section 95892(d)(1), (3) <br />and (5) of the regulations as follow: <br />"Proceeds obtained from the monetization of allowances directly allocated to a publicly owned <br />electric utility shall be subject to any limitations imposed by the governing body of the utility and to <br />the additional requirements set forth." <br />"Auction proceeds and allowance value obtained by an electrical distribution utility shall be used <br />exclusively for the benefit of retail ratepayers of each electrical distribution utility, consistent with <br />the goals of AB 32, and may not be used for the benefit of entities or persons other than such <br />ratepayers." <br />