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Page 1: SeattleCityLight-2013-EIA-Report - Washington State …€¦ · XLS file · Web view · 2017-12-12Instructions Renewables Example Renewables Report Conservation Report Report Submittal

Utility Seattle City LightReport Submittal Date May 30, 2013

Utility Contact Name/Dept. Mike LittlePhone 206-684-3323Email

2012 - 2013 Planning

Total 1,051,375.2 210,327.6

Achievement2012 Achievement

Conservation by Sector MWh Residential 36,328 12,125,140 Commercial 44,039 14,456,681

Industrial 7,610 1,604,868 Agriculture

Distribution Efficiency Production Efficiency

NEEA 27,734 1,631,620

Total 115,711 29,818,309

Energy Independence Act (I-937) Conservation Report

[email protected]

Planning

Ten Year Potential (MWh)

2012 - 2013 Target (MWh)

Utility Expenditures ($)

Conservation expenditures NOT included in sector

expenditures

Page 2: SeattleCityLight-2013-EIA-Report - Washington State …€¦ · XLS file · Web view · 2017-12-12Instructions Renewables Example Renewables Report Conservation Report Report Submittal

Utility Seattle City Light

Methodology Narrative: See instructions

In setting the 2012-2013 energy conservation target, Seattle City Light used the Utility Analysis Option outlined in WAC 194-37-070. A conservation potential assessment was completed in May, 2012 and is posted on Seattle City Light's website (link provided below).

The conservation potential assessment established the 2012-2013 target at 24.01 aMW (210,327.6 MWh) and a ten-year potential of 120.02 aMW (1,051,375.2 MWh). The Seattle City Council Energy and Environment Committee agenda for Tuesday, January 24, 2012 (attached) included Resolution #31352 to approve the target/potential and indicated that this agenda item was noted as a Public Hearing in compliance with I-937. The 2012-2013 target and the ten-year potential were approved by the Seattle City Council at the Full Council meeting (agenda attached) on January 30, 2012 when Resolution #31352 (attached) was signed.

Seattle City Light's Conservation Potential Assessment: http://www.seattle.gov/light/Conserve/docs/SCLCPAFinalReport_05292012.pdf

Page 3: SeattleCityLight-2013-EIA-Report - Washington State …€¦ · XLS file · Web view · 2017-12-12Instructions Renewables Example Renewables Report Conservation Report Report Submittal

Utility Seattle City Light

Conservation Notes:

The 115,711 MWh achieved in 2012 represents approximately 55% of the 2012-2013 biennial target of 210,327 MWh. This achievement reflects the most current data available. Seattle City Light is relying on BPA's IS 2.0 reporting system to capture all the energy conservation savings for 2012. However, SCL and BPA have not formally reconciled all the energy savings reported to BPA for this time period and in the short term, some very minor discrepancies may occur. Over the next few months, BPA and SCL will work to reconcile the energy savings reported to BPA and at that point we will be in a much better position to provide a more accurate accounting of the energy savings delivered for SCL.

This report reflects energy savings from projects completed in calendar year 2012 and includes both the direct and indirect savings from NEEA's efforts. It also includes energy savings delivered through the Energy Smart Grocer Program delivered by Portland Energy Conservation Inc. (PECI). While SCL anticipates significant energy savings from the OPower delivered Home Electricity Report Program, this report does not include any savings associated with that program. SCL is evaluating the energy savings from the OPower program and the results will be available for the 2014 report.

Page 4: SeattleCityLight-2013-EIA-Report - Washington State …€¦ · XLS file · Web view · 2017-12-12Instructions Renewables Example Renewables Report Conservation Report Report Submittal

Utility Seattle City LightReport Submittal Date 30-May-13

Utility Contact Name/Dept Robert W. Cromwell, Jr.Phone 206-684-3856Email

Compliance Method

19.285.040 (2)(a) RPS Target 19.285.040 (2)(d) No Load Growth19.285.050 Resource Cost

Loads and Resources2011 Annual Load (MWh) 9,600,232

2012 Annual Load (MWh) 9,466,642Average of 2011 & 2012 Loads (MWh) 9,533,437

2013 Eligible Renewable Energy Target (% of load) 3%2013 Eligible Renewable Energy Target (MWh) 286,003

Eligible Renewables Acquisitions / Investments (MWh) 286,003

(a) (c) (h)

Water Wind Landfill Gas Biodiesel Apprentice Labor

MWh MWh MWh MWh MWh MWh MWh MWh MWh MWh equivalent MWh equivalent

Eligible Renewable Resources (MWh) 1,595 258,408 - - - - - - - - - Renewable Energy Credits (MWh) 26,000 - - - - - - - - -

Total Renewables (MWh) 1,595 284,408 - - - - - - - - -

Energy Independence Act (EIA) Renewable Energy Report

[email protected]

     (b)      (d)      (e)      (f)      (g)      (i)

Solar Energy

Geothermal Energy

Wave, Ocean, Tidal

Gas from Sewage

TreatmentBiomass Energy Distributed Generation

Reporting Year:This renewable energy report summarizes the eligible renewables resources and renewable energy credits (RECs) that the utility has acquired by January 1, 2013 for the purpose of meeting its Energy Independence Act (EIA) renewables target for 2013. The actual resources and RECs used to comply with  the 2013 EIA target may vary from those reported here. Utilities will report in June of 2015 on the actual results for 2013.

Compliance Methods: The EIA provides three compliance methods for utilities:-- Meet the renewable energy target using any combination of renewable resources and RECs. The target for 2013 is 3% of the utility’s load-- Invest at least 4% of the utility’s annual revenue requirement in the incremental cost of renewable resources and RECs.-- Invest at least 1% of its annual revenue requirement in renewable resources and RECs. This option is available only to certain utilities that are not growing and not buying new non-renewable resources.

All utilities must report the renewable resources and RECs acquired for the 2013 target year. Utilities that elect to use a compliance method based on renewable investments must provide additional information demonstrating compliance with that method.

NOTE: This is a general explanation of the renewable energy requirements of the Energy Independence Act, intended to help members of the public understand the information reported by the utility. Consult Chapter 19.285 RCW and Chapter 194-37 WAC for details.

x

Page 5: SeattleCityLight-2013-EIA-Report - Washington State …€¦ · XLS file · Web view · 2017-12-12Instructions Renewables Example Renewables Report Conservation Report Report Submittal

Renewable Resources Utility Seattle City LightCompliance Year 2013

(a) (c) (h)

Water Wind Landfill Gas Biodiesel Apprentice Labor

Facility Name MWh MWh MWh MWh MWh MWh MWh MWh MWh MWh equivalent MWh equivalent

Stateline (2013) 258,408 Wanapum Future Unit Fish Bypass 1,595

Note: Investor Owned Utilities may complete this page or attach their Utilities and Transportation Commission Renewable and Conservation filings for 2013.

     (b)      (d)      (e)      (f)      (g)      (i)

Solar Energy

Geothermal Energy

Wave, Ocean, Tidal

Gas from Sewage

TreatmentBiomass Energy Distributed Generation

Page 6: SeattleCityLight-2013-EIA-Report - Washington State …€¦ · XLS file · Web view · 2017-12-12Instructions Renewables Example Renewables Report Conservation Report Report Submittal

Renewable Energy Credits Utility Seattle City LightCompliance Year 2013

(a) (c) (h)

Water Wind Landfill Gas Biodiesel Apprentice Labor

Facility Name,GUID,(REC Vintage) MWh MWh MWh MWh MWh MWh MWh MWh MWh MWh equivalent MWh equivalent

Stateline (W248, W249) via BPA (2013) 11,000 Condon (W774) via BPA (2013) 6,000

Klondike I (W238) via BPA (2013) 3,000 Klondike III (W237) via BPA (2013) 6,000

     (b)      (d)      (e)      (f)      (g)      (i)

Solar Energy

Geothermal Energy

Wave, Ocean, Tidal

Gas from Sewage

TreatmentBiomass Energy Distributed Generation

Page 7: SeattleCityLight-2013-EIA-Report - Washington State …€¦ · XLS file · Web view · 2017-12-12Instructions Renewables Example Renewables Report Conservation Report Report Submittal

Utility Seattle City LightTarget Year 2013

Renewables Notes: Incremental spending is estimated at 0.58% of 2013 total retail revenue.City Light has other sources of eligible RECs it may use for compliance.

Page 8: SeattleCityLight-2013-EIA-Report - Washington State …€¦ · XLS file · Web view · 2017-12-12Instructions Renewables Example Renewables Report Conservation Report Report Submittal

Utility ExampleReport Submittal Date

Utility Contact Name/DeptPhoneEmail

Compliance Method

X 19.285.040 (2)(a) RPS Target 19.285.040 (2)(d) No Load Growth19.285.050 Resource Cost

Loads and Resources2011 Annual Load (MWh) 1,886,814

2012 Annual Load (MWh) 1,849,078Average of 2011 & 2012 Loads (MWh) 1,867,946

2013 Eligible Renewable Energy Target (% of loads) 3%2013 Eligible Renewable Energy Target (MWh) 56,038

Eligible Renewables Acquisitions / Investments (MWh) 60,482

(a) (c) (h)

Water Wind Landfill Gas Biodiesel Apprentice Labor

MWh MWh MWh MWh MWh MWh MWh MWh MWh MWh equivalent MWh equivalent

Eligible Renewable Resources (MWh) - 52,450 - - - - - - 2,286 954 - Renewable Energy Credits (MWh) 3,150 - - - - - - 1,000 630 12

Total Renewables (MWh) - 55,600 - - - - - - 3,286 1,584 12

Energy Independence Act (EIA) Renewable Energy Report EXAMPLE

     (b)      (d)      (e)      (f)      (g)      (i)

Solar Energy

Geothermal Energy

Wave, Ocean, Tidal

Gas from Sewage

TreatmentBiomass Energy Distributed Generation

Reporting Year:This renewable energy report summarizes the eligible renewables resources and renewable energy credits (RECs) that the utility has acquired by January 1, 2013 for the purpose of meeting its Energy Independence Act (EIA) renewables target for 2013. The actual resources and RECs used to comply with  the 2013 EIA target may vary from those reported here. Utilities will report in June of 2015 on the actual results for 2013.

Compliance Methods: The EIA provides three compliance methods for utilities:-- Meet the renewable energy target using any combination of renewable resources and RECs. The target for 2013 is 3% of the utility’s load-- Invest at least 4% of the utility’s annual revenue requirement in the incremental cost of renewable resources and RECs.-- Invest at least 1% of its annual revenue requirement in renewable resources and RECs. This option is available only to certain utilities that are not growing and not buying new non-renewable resources.

All utilities must report the renewable resources and RECs acquired for the 2013 target year. Utilities that elect to use a compliance method based on renewable investments must provide additional information demonstrating compliance with that method.

NOTE: This is a general explanation of the renewable energy requirements of the Energy Independence Act, intended to help members of the public understand the information reported by the utility. Consult Chapter 19.285 RCW and Chapter 194-37 WAC for details.

Page 9: SeattleCityLight-2013-EIA-Report - Washington State …€¦ · XLS file · Web view · 2017-12-12Instructions Renewables Example Renewables Report Conservation Report Report Submittal

Renewable Resources Utility ExampleCompliance Year 2013

(a) (c) (h)

Water Wind Landfill Gas Biodiesel Apprentice Labor

Facility Name MWh MWh MWh MWh MWh MWh MWh MWh MWh MWh equivalent MWh equivalent

IP-Springfield Containerboard Mill 2,286 GREEN RIDGE POWER LLC (5.9 MW) 25,950

Hopkins Ridge 12,650 954 Hopkins Ridge Phase II 13,850

Note: Investor Owned Utilities may complete this page or attach their Utilities and Transportation Commission Renewable and Conservation filings for 2013.

     (b)      (d)      (e)      (f)      (g)      (i)

Solar Energy

Geothermal Energy

Wave, Ocean, Tidal

Gas from Sewage

TreatmentBiomass Energy Distributed Generation

Page 10: SeattleCityLight-2013-EIA-Report - Washington State …€¦ · XLS file · Web view · 2017-12-12Instructions Renewables Example Renewables Report Conservation Report Report Submittal

Renewable Energy Credits Utility ExampleCompliance Year 2013

(a) (c) (h)

Water Wind Landfill Gas Biodiesel Apprentice Labor

Facility Name,GUID,(REC Vintage) MWh MWh MWh MWh MWh MWh MWh MWh MWh MWh equivalent MWh equivalent

Roosevelt Biogas #1 - LFG Engine #3, W826, (2013) 500 12 Roosevelt Biogas #1 - LFG Engine #1, W824, (2013) 500 Lower Snake River - Dodge Junction, W2669,(2012) 1,150 230 Lower Snake River - Dodge Junction, W2669,(2013) 2,000 400

     (b)      (d)      (e)      (f)      (g)      (i)

Solar Energy

Geothermal Energy

Wave, Ocean, Tidal

Gas from Sewage

TreatmentBiomass Energy Distributed Generation

Page 11: SeattleCityLight-2013-EIA-Report - Washington State …€¦ · XLS file · Web view · 2017-12-12Instructions Renewables Example Renewables Report Conservation Report Report Submittal

Utility ExampleTarget Year 0

Renewables Notes:

Page 12: SeattleCityLight-2013-EIA-Report - Washington State …€¦ · XLS file · Web view · 2017-12-12Instructions Renewables Example Renewables Report Conservation Report Report Submittal

May 2013

CONSERVATION WORKSHEET

Energy Independence Act (I-937) Report Workbook Instructions

Deadline: Friday, June 1, 2013, 11:59 pm PDTSubmission: Email this Workbook and any supporting documentation to [email protected] Questions: Chuck Murray, State Energy Office, (360) 725-3113

The Energy Independence Act (EIA) “RCW 19.285.070, Reporting and public disclosure” requires each qualifying utility to develop an annual report describing compliance with the Act. Commerce has developed this template to aide in consistent reporting from all utilities. This template only requests the data needed to complete the public reporting requirement. Additional documentation may be necessary to demonstrate full compliance with EIA. The EIA reports will be made available to the public via Commerce’s Website, www.commerce.wa.gov/energy.

Excel Report Workbook: Contains one worksheet for Renewables and one for Conservation.

Each worksheet includes formulae for drawing results from input. Gray areas are for data input. Yellow areas are supported by formulas and require no inputs. In some cases you will want to skip over a yellow section because it summarizes detailed data that follow. The Workbook requests numeric summaries as well as narratives and supporting notes. Commerce relies on the utilities to provide enough detail in the written section to ensure members of the public understand the data provided. Please submit this Workbook in Excel format (i.e., do not submit in PDF format).

Attachments: If you provide supporting documentation, Commerce will post that material along with your Excel Workbook. Please provide a reference to any attachments in the primary Excel workbook.

Mid-Term Reporting Context: This report summarizes 2012 conservation achievement halfway through the 2012-13 biennium. In the “Achievement” section include only values that have been documented to date. Do not include anticipated achievements. If you would like to discuss pending achievements, do so in the “conservation notes” section of this worksheet.

Conservation Notes: At the end of this worksheet you will find a text box called “Conservation Notes”. This is a place for any explanatory statements, web links or references the utility would like to include.

Utility Name and Contact Information: Complete each field.

Planning: In the planning section the utility is asked to provide the ten year potential and the two year target for the 2012-13 biennium.

Achievement: Report electrical savings and conservation program cost in this section. The report shall include total electricity savings and cost by customer sector (residential, commercial, industrial, and agricultural), by production efficiencies, and by distribution efficiencies. The sectors listed are per WAC 194-37-060. Because it is a major category, we have listed NEEA separately.

Blank rows have been provided under sector-specific achievement and expenditures. If a utility summarizes data differently, or includes additional sector categories, it must add a sector name and enter the values. This may apply to investor-owned utilities that divide sectors differently. This may also be necessary to account for third-party programs, federal and state efficiency standards, or codes.

Conservation Expenditures NOT included in Sector Expenditures: Some utilities have indicated they do not break down expenditures on staff, overhead, information services or other conservation- related expenses by sector. If that is the case, provide additional cost-related information in this section of the worksheet. Do not include energy savings estimates in this section, just cost.

Page 13: SeattleCityLight-2013-EIA-Report - Washington State …€¦ · XLS file · Web view · 2017-12-12Instructions Renewables Example Renewables Report Conservation Report Report Submittal

Methodology: Briefly describe the methodology used to establish the utility's ten-year potential and biennial targets. Utilities are expected to provide sufficient detail for full public disclosure. We recommend you reference any detailed plans as approved by consumer owned utility governing authorities or investor owned utility regulators. Include web site addresses and utility contact information for referenced documentation. Add additional pages as necessary or provide references to attachments.

Depending on which methodology (per WAC 194-37-070) the utility uses to develop its conservation potential and target, the following documentation is recommended:

1. Conservation Calculator Option: WAC 194-37-070(4)Provide a brief narrative noting use of the conservation calculator and respond to details requested below. Provide the version number of the calculator used. Which calculator “Option” did the utility choose? In creating the ten-year potential, did the utility deduct energy savings achieved in a previous biennium as allowed by WAC 194-37-070(4)(c)? For example, if a utility achieves more conservation than envisioned by the calculator in a particular sector, and that conservation meets certain criteria as provided in WAC 194-37-080(2), the utility has the option to decrease the conservation potential in that sector from the calculator in the subsequent biennium. o How many MWh were deducted over the ten-year planning period? o How many MWh were deducted from the 2012-2013 targets? How were production and distribution efficiencies calculated and included in the target? o Was the distribution efficiency potential taken from the Council’s calculator used by the utility or was it developed using the utility analysis option? WAC 194-37-070(3)(a). Describe how utility determined two-year target based on pro rata share of its ten-year potential.

Provide references to public meetings held to develop and approve the conservation plan and targets. This includes meetings that provided an opportunity for public comment on the utility’s assessment of conservation potential, and meetings at which the board approved the conservation potential and biennial target. WAC 194-37-070(2).

2. Modified Conservation Calculator Option: WAC 194-37-070(5)Provide a brief narrative noting the use of the conservation calculator. Provide a brief description of the modifications made to the calculator. Address each step as outlined in WAC 194-37-070(5)(a-g). Provide a copy of the analysis as an attachment or a web reference. Also address the following in the narrative: Provide the version number of the calculator used. Which calculator “Option” did the utility choose? Which calculator “Option” did the utility choose? How were production and distribution efficiencies calculated and included in the target? o Was the distribution efficiency potential taken from the Council’s calculator used by the utility or was it developed using the utility analysis option? WAC 194-37-070 (3)(a). Describe how utility determined two-year target based on pro rata share of its ten-year potential.

Provide references to public meetings held to develop and approve the conservation plan and targets. This includes meetings that provided an opportunity for public comment on the utility’s assessment of conservation potential and meetings at which the board approved the conservation potential and biennial target. WAC 194-37-070(2).

Utility Analysis Option: WAC 194-37-070(6)For this section we ask the utility to provide a copy of the utility conservation analysis or a web link to the document. Provide a brief narrative describing the selection of the utility analysis option.

In addition we ask that the utility provide references to public meetings held to develop and approve the conservation plan and targets. This includes meetings which provided an opportunity for public comment regarding its assessment of conservation potential and meetings where the board approved the conservation potential and biennial target. WAC 194-37-070(2).

Page 14: SeattleCityLight-2013-EIA-Report - Washington State …€¦ · XLS file · Web view · 2017-12-12Instructions Renewables Example Renewables Report Conservation Report Report Submittal

RENEWABLE ENERGY WORKSHEETThis worksheet covers the universal renewable energy reporting requirements of the EIA (RCW 19.284.040(2)(a). Additional reporting is required for compliance options 19.285.040(2)(d), “no load growth” and RCW 19.285.050, “cost cap”. These are discussed later in the instructions.

Mid-Term Reporting Context: The June 1, 2013 EIA renewable energy report summarizes the eligible renewables resource and/or renewable energy credits that the utility has acquired and or has under contract by January 1, 2013 for the purpose of meeting its 2013 renewables target if the utility choose to use the compliance path in RCW 19.285.040(2)(a). This describes the renewables acquisitions and or investments made prior to the beginning of the target year to meet the requirements of the EIA. This is the only renewable energy reporting required this year.

Beginning in June 2014, Commerce will also ask utilities to report on the actual renewables performance from two years back (i.e., 2012). The June 1, 2014 report will include this summary of renewables performance for target year 2012. This will include megawatt-hours that were actually brought to load by December 31 of the target year and /or renewable energy credits used or invested in to comply with the EIA. This look-back will include any reduction in a utility’s renewable energy target due to use of the force majeure clause in RCW 19.285.040(2)(i).

Worksheet Organization: The first page of the renewables worksheet establishes targets and summarizes detailed reporting from pages 2 and 3. Page 2 provides facility level reporting for renewable resources. Page 3 provides facility level reporting for renewable energy credits. Page 4 provides a text box where the utility may include explanatory statements, references or web links to supporting information.

Compliance Method: Select one or more of the three compliance methods that the utility intends to use. The EIA provides three compliance methods. A utility must make that determination by January 1, 2013 and must include information establishing its compliance method in this report.

Load and Resource ReportingRCW 19.285.070 requires that each qualifying utility report: Annual load for the prior two years Amount of megawatt-hours needed to meet the annual renewable energy target Amount of megawatt-hours of each type of eligible renewable resource acquired Type and amount of renewable energy credits acquired

2011 Annual Load (MWh): Load delivered to retail customers in Washington

2012 Annual Load (MWh): Load delivered to retail customers in Washington

Average of 2011 and 2012 Loads (MWh): Calculated = average of 2011 and 2012 loads

Statutory Target 2012 to 2015 = 3 percent

2013 Renewable Energy Target (MWh): Calculated = Statutory Target multiplied by Average Load

Megawatt-hours of each type of eligible renewable resource: Rows 21-23 summarize more detailed data entered on pages 2 and 3 below. Do not enter data in these sections.

[Row 15] 2013 Renewable Energy Acquired* (MWh): Calculated = sum of the row 23, Total Renewables

[Row 23] Total Renewables: Row 21+Row 22

Page 15: SeattleCityLight-2013-EIA-Report - Washington State …€¦ · XLS file · Web view · 2017-12-12Instructions Renewables Example Renewables Report Conservation Report Report Submittal

Note for Investor Owned Utilities (IOUs): Details on page 2 and 3 are designed to meet reporting requirements for consumer-owned utilities. The Utilities and Transportation Commission and IOUs have developed their own report form that details renewable energy achievements. Commerce requests that IOUs complete page 1 of the renewable worksheet, including rows 21 and 22. When completed, Commerce will attach the reports provided under 480-109-040 WAC to complete the details.

[Page 2] Renewable Resources: This table provides reporting of renewable resource generation (MWh) by facility and renewable energy type. It includes facility level entries for Apprentice Labor and Distributed Generation credits. For each facility, enter the renewable energy generation in the appropriate column by type. If generation is eligible for Apprentice Labor or Distributed Generation credits enter these in the appropriate column. For example, a wind facility meeting the apprentice labor requirements will report wind generation in column E and apprentice labor MWh equivalents in column l.

[Page 3] Renewable Energy Credits: This table provides reporting of renewable energy credits (MWh) by facility and renewable energy type. It includes facility level entries for Apprentice Labor and Distributed Generation credits. In the facility column, include the facility name, the WREGIS generating unit identification number (GUID) and the vintage of the renewable energy credits (RECs). For facilities where RECs from two different years from the same facility are used, provide two rows for entry. In the following example, Lower Snake River - Dodge Junction, W2669, the vintage is noted twice---in 2012 and in 2013.

Facility Name, GUID, (REC Vintage) Roosevelt Biogas #1 - LFG Engine #3, W826, (2013) Roosevelt Biogas #1 - LFG Engine #1, W824, (2013) Lower Snake River - Dodge Junction, W2669, (2012) Lower Snake River - Dodge Junction, W2669, (2013)

Additional reporting for compliance option 19.285.040(2)(d), “no load growth” Utilities choosing compliance using the no-load growth method are asked to detail their reporting in a narrative. In the notes provide a clear statement of the utility’s intention to qualify using the no-load growth option. Details can be included in the notes section or as an attachment. Utilities choosing compliance using the no-load growth method should provide a detailed narrative report. In the notes provide a clear statement of the utility’s intention to qualify using the no-load-growth option. Details can be included in the notes section or as an attachment. The decision to use this compliance option was to have been made prior to January 1 of the target year. Utilities need to document when the decision was made to pursue this compliance method. Consumer-owned utilities should summarize documentation required by WAC 194-37-140. Investor-owned utilities should provide a summary of documentation required by the Utilities and Transportation Commission.

Additional reporting for compliance option RCW 19.285.050, “cost cap” Utilities showing compliance using the cost cap method should provide a detailed narrative report. In the notes provide a clear statement of the utility’s intention to qualify using the cost-cap option. Details can be included in the notes section or as an attachment. The decision to use this compliance option was to have been made prior to January 1 of the target year. Utilities need to document when the decision was made to pursue this compliance method. Consumer-owned utilities should summarize documentation required by WAC 194-37-160. Investor owned utilities should provide a summary of documentation required by the Utilities and Transportation Commission.

[Page 4] Notes: Provide any additional information needed to support your renewables data.