I-937 Compliance

On May 31, 2013, Snohomish County PUD submitted its progress report to the Washington State Department of Commerce for its compliance for conservation and renewable resources pursuant to the Energy Independence Act (EIA), adopted by Washington state voters in 2006.

The EIA enacted a renewable portfolio standard (RPS), commonly referred to as “Initiative 937,” and requires Washington state electric utilities serving 25,000 or more customers to:

  • Undertake all cost-effective energy conservation; and
  • Obtain a specified portion of their electricity from new renewable resources and allows for three different compliance method described below. 

Snohomish PUD reported it had achieved energy conservation for calendar year 2012 in the amount of 100,029 megawatt-hours (MWh), which is more than 64% of its 2012-2013, or  biennial conservation target of 164,317  MWh.

For renewable resources, Initiative 937 provides three different methods by which a utility can demonstrate it is compliant with the RPS standard and the amount of renewable resources a utility must include in its power supply portfolio to serve its customers:

  • Compliance Method 1 – Renewables Target: A qualifying utility must serve its load with a certain percentage or target of eligible renewable generation by a certain date. The targets are 3% of load by 2012, 9% by 2015 and 15% by 2020; or 
  • Compliance Method 2 – No Load Growth/1% Investment: A qualifying utility can demonstrate compliance if it can show it has experienced minimal or no load growth over a three-year period; has only acquired renewable energy or has offset non-renewable energy with renewable energy credits (RECs); and has invested at least 1% of its total retail revenue requirement in renewable energy or RECs; or
  • Compliance Method 3 – Incremental Resource Cost /4% Investment: A qualifying utility can demonstrate compliance if the utility can demonstrate it has invested at least four percent of its total annual retail revenue requirement on the incremental cost of renewable resources that meet the RPS.  Under this compliance method a utility calculates the incremental cost of its renewables resources that satisfy the RPS compared to an alternate or non-renewable resource or resources.  

For the 2013 period, the PUD elected to demonstrate its compliance with the EIA RPS using Compliance Method 3, the Incremental Resource Cost method. Per the Revised Code of Washington Chapter 19.285, Section 050 states that a qualifying utility will be considered in compliance with the annual target created in the EIA for a given year if the utility invested four percent (4%) of its total annual retail revenue requirement on the incremental costs of eligible renewable resources, renewable energy certificates (RECs) or a combination of the two. The PUD’s investment in renewable energy for 2013 is approximately $33 million. This incremental resource cost exceeds the 4% investment level which is equivalent to $21.5 million.

For reporting purposes, the PUD has forecast  it will generate more than 629,440 MWh from its renewable resources during calendar year 2013.  This forecast exceeds the 3% target of 201,260 MWh of renewable energy that would be required if the PUD elected to meet its obligations under Compliance Method 1.

Snohomish County PUD is in compliance with the EIA for the 2013 compliance year.

Supporting documents to the reports listed above are available upon request or can be viewed at the Department of Commerce's website (click here).