EWEB 2011 RPS Compliance Report Page 1 

Eugene Water Electric Board

Oregon Renewable Portfolio Standard

2012 Compliance Report 

and

2013 – 2030 Implementation Plan

June 1, 2013
EWEB 2011 RPS Compliance Report Page 2 

Introduction 

In 2007 Oregon enacted Senate Bill 838, the Oregon Renewable Energy Act, which created a 

Renewable Portfolio Standard (RPS) that all Oregon electric utilities must follow. The purpose 

of the RPS is to decrease Oregon utilities reliance on fossil fuels for electric generation and 

increase their use of renewable energy sources.

The Act established standards for Oregon’s electric utilities requiring that a percentage of their 

annual sales must come from qualifying renewable resources beginning in 2012. The exact 

percentage requirement and the year the requirement begins differs for large and small electric 

utilities, which are shown in Figure 1. The size of the utility is a percentage of Oregon’s total 

retail electric sales in the year. EWEB is the only Consumer Owned Utility (COU) classified as 

a large electric utility, along with PacifiCorp and Portland General Electric. All of Oregon’s other 

COUs are classified as small electric utilities, which under the Act do not have compliance 

obligations until 2025.

Figure 1. Annual percentage target of qualifying electricity by year

Utility Size 2012 2015 2020 2025

Large Utilities 3% or more 5% 15% 20% 25%

Smaller Utilities From 1.5% to 3% 10%

Smallest Utilities Under 1.5% 5%

The Act also defines which types of renewable generation are considered qualifying electricity. 

In general, qualifying renewable resources must have an on-line date of January 1, 1995 or 

later, with some exceptions.1

 

There are four exemptions in the Act that allow utilities to reduce the annual compliance target: 

x Would cause the utility to spend over 4% of annual costs to comply with RPS. 

x Force Consumer Owned Utilities (COU) to replace BPA Tier 1 power with new 

renewable electricity.

x Force a utility to acquire resources in excess of their load requirement.

x Force a utility to replace older renewable or nonfossil fuel generation (i.e. legacy hydro 

projects) with new renewable generation.

These exemptions are very significant to EWEB, because the vast majority of our resources are 

from BPA Tier 1 resources and EWEB owned or contracted for legacy hydro. 

In addition to the above exemptions, there are mechanisms written into the Act that are 

designed to put a cap on the cost of complying with the RPS. The Act also requires Oregon 

utilities to offer customers the option of purchasing renewable energy. EWEB’s Greenpower 

program, implemented prior to the passage of the Act, is an example of such a voluntary retail 

renewable purchase program. 

 

1 See Attachment 1, Table 2 for a list of conditions under which pre-1995 resources that eligible to 

produce qualifying electricity. A later amendment to the RPS allows for pre-1995 woody biomass to 

qualify, but the RECs will not be eligible for use in compliance until 2026. 
EWEB 2011 RPS Compliance Report Page 3 

The Oregon Public Utilities Commission (PUC) oversees Investor Owned Utilities (IOU) 

reporting and compliance with the RPS. Because the PUC does not generally regulate Oregon 

COUs, the statute governing compliance reports, ORS 469A.170, states “A consumer-owned 

utility shall make the report to the members or customers of the utility.” This report is EWEB’s 

report to our Board and customers. 2

RPS Compliance rules 

The RPS requires that utilities include in their portfolio of power sold to retail customers a 

percentage of electricity generated from qualifying renewable energy sources. Measurement of 

compliance is based on annual MWh of retail sales and qualifying generation. Retail sales are 

based on EWEB’s audited retail sales. 

Per rules adopted by the Oregon Department of Energy, qualifying generation volumes are 

based on values recorded and reported by the Western Renewable Energy Generation 

Information System (WREGIS). WREGIS is a large database that receives monthly generation 

volumes of renewable generation. Each MWh of renewable generation equals one Renewable

Energy Certificate (REC). Each REC has a unique identification number that indicates the 

generation project and the month the electricity was generated. The purpose of this system is 

to insure that renewable generation and its associated REC are not used to meet the 

requirements of more than one program. WREGIS stores RECs from EWEB generation and 

long-term renewable power purchases as well as any short-term unbundled REC purchases. 

The compliance target for EWEB in 2012 is 5% of retail sales, subject to the four exemptions 

that can reduce the compliance target. Compliance is demonstrated by retiring a quantity of 

WREGIS RECs equal to the compliance target. Once a REC is retired in WREGIS it is no 

longer available to be used in any other program. But, as long as a REC has not been retired it 

can be retained for future compliance use or sold to another entity. 

Two exemptions significantly reduce EWEB’s current and projected compliance targets. The 

first exemption releases EWEB from reducing purchases of BPA Tier 1 energy in order to take 

in qualifying electricity. The second exemption releases EWEB from replacing energy produced 

by non-fossil resources (such as our legacy hydro) with qualifying electricity. 

The policy rationale for these exemptions is that the intent of the RPS is to displace fossil fuels, 

not to require EWEB to replace renewable energy from our existing legacy hydro projects with 

renewable energy from new projects. The Act strikes a balance in doing no harm to the many 

legacy hydro projects in the Northwest while disqualifying them from creating RECs, in order to 

promote the deployment of new renewable generation projects to displace fossil fuels and spur 

economic development. Exempt resources cannot be used to meet RPS compliance, used for 

our Greenpower program, or sold, but they will not be equated with fossil fuel resources either.

EWEB’s generation portfolio is overwhelmingly supplied from BPA Tier 1 power and our legacy 

hydro generation. Under Oregon’s RPS rules, if exempt generation in 2012 exceeds 95% of 

total retail sales then EWEB can reduce the 5% compliance target by the amount the exempt 

generation exceeds 95%. If exempt generation exceeds 100% of total retail sales then EWEB 

can reduce its compliance target to zero. 

 

2 For additional information on the Oregon RPS see 

http://www.oregon.gov/energy/RENEW/Pages/RPS_home.aspx
EWEB 2011 RPS Compliance Report Page 4 

2012 RPS Compliance Information 

RPS compliance is measured in annual MWh. Figure 2 contains annual MWh information used 

to calculate EWEB’s RPS compliance. 

Figure 2. EWEB 2012 RPS Compliance Obligation Calculations

MWh

Retail Sales 2,375,070

RPS Target 5%

RPS obligation BEFORE exempt 118,734

Exempt resources

 BPA Tier 1 purchases 2,601,050 

 Mid-C hydro (contract) 17,137 

 EWEB hydro (owned) 605,433 

Total exempt resources 3,223,620 

Fraction of EWEB sales from 

exempt resources 136%

RPS obligations AFTER exempt 0

Although EWEB does not have any compliance obligation in 2012 due to exempt hydro 

generation, Figure 3 lists those qualifying renewable generation volumes that would have been 

available to meet compliance had there been a demonstrated need.

Figure 3. EWEB 2012 WREGIS RECs and Banked Inventory

MWh

State Line Wind 54,398

Klondike III Wind 63,956

Harvest Wind (owners share) 48,574

Foote Creek Rim I Wind 16,968

Metro Wastewater biogas 5,108

Seneca Cogen 110,104

Solar PV 1,982

Total RECs generated in 2012 303,115

Total RECs purchased in 2012 26,381

Total banked REC inventory 

as of Dec 31, 2011 823,514

Total RECs available in 2012 1,153,010
EWEB 2011 RPS Compliance Report Page 5 

EWEB acquired renewable resources ahead of need, and under Oregon’s RPS rules surplus 

RECs can be banked indefinitely for future compliance. Therefore, EWEB is well positioned to 

meet future RPS compliance, as will be discussed in the section 2013 – 2030 Implementation 

Plan below. 

Other uses of RECs in 2012 

Greenpower sales

The Greenpower program allows customers the choice to voluntarily pay an additional one cent 

per kWh towards new renewable generation. Just as RECs are retired to satisfy any obligations 

under the mandatory RPS, RECs are also retired to match the volume of sales under EWEB’s 

voluntary retail Greenpower program, with one REC retired for every MWh of program sales. 

In 2012 sales to EWEB customers under the Greenpower totaled 31,797 MWh. EWEB has 

retired this amount of RECs from our available portfolio of renewable generation. For 

additional information on EWEB’s Greenpower program please see 

http://www.eweb.org/greenpower .

Wholesale REC sales

One of the justifications for creating the WREGIS system to track RECs was to facilitate the 

purchase and sales of RECs between those with generation and those that need RECs for 

compliance. Renewable generation from hydro, wind, and solar is variable, so it is likely that 

utilities will either have too little or too much generation in any year. The WREGIS system 

facilitates the trading of these REC imbalances across the western electric interconnect. This 

reduces the cost of RPS compliance because utilities can purchase the last increment of need 

instead of building resources that are unneeded most years. 

EWEB has acquired several renewable resources over the last decade that are surplus to the 

projected needs of our customers. We sell the power into wholesale markets as it is generated. 

EWEB sells some of our surplus RECs to other businesses and utilities in the wholesale market 

when the offered price is attractive. The remainder of EWEB’s surplus RECs are banked and 

available for future RPS compliance needs. 

In 2012 EWEB sold a total of 244,341 RECs bringing in revenue of over $1.7 million that helped 

to offset cost increases in other parts of EWEB’s budget. 

Figure 4 shows EWEB’s REC portfolio balance at the end of 2012 after including these two 

additional uses. 

Figure 4. EWEB Ending 2012 Banked Inventory

MWh

Total RECs available in 2012 1,153,010

less

 Greenpower retirements 31,797

 Wholesale sales 244,341

Total banked REC inventory 

as of Dec 31, 2012 876,872
EWEB 2011 RPS Compliance Report Page 6 

2013 – 2030 Implementation Plan 

Since the mid-1990s EWEB built or purchased the output of portions of four wind projects, two 

biomass cogeneration projects, one biogas cogeneration project, and numerous small local 

solar PV projects that can create RECs. These projects were acquired as part of a long-term 

vision for a diverse future resource portfolio. 

EWEB’s resource portfolio without these new resources consists of our BPA Tier 1 contract and 

EWEB’s legacy hydro projects constructed prior to 1995. As explained above, these resources

do not create RECs, but their generation is exempt from displacement in the RPS compliance 

target. 

Due to the closure of the Hynix semiconductor plant in Eugene and other economic factors,

forecast retail sales for EWEB have fallen to a level that can be served by our exempt resources 

in even the driest years. In the 2012 Integrated Electric Resource Plan EWEB adopted a 

strategy of acquiring conservation sufficient to keep EWEB loads from growing in the future. 

Therefore, as long as EWEB’s retail sales do not increase significantly above the forecast, our 

exempt resources will continue to equal or exceed retail sales. Coupled with the renewable 

resources acquired in the last decade EWEB is well positioned to meet forecast future RPS 

compliance and Greenpower sales. 

Figure 5 shows the forecast supply and uses of RECs between 2013 and 2030. The black line 

represents forecast annual REC supply from EWEB generation. It declines late in the forecast 

due to the termination of three long-term power purchases of wind and biomass generation. 

The chart shows both forecasts for Greenpower sales and existing wholesale sales. The figure

shows no RPS obligations because under a moderately dry water year, 90% of normal hydro, 

EWEB’s exempt resources exceed our forecast load throughout the planning horizon. Even 

under extreme drought conditions EWEB still has sufficient exempt resources to avoid any RPS 

compliance obligations assuming the current load and resource mix.
EWEB 2011 RPS Compliance Report Page 7 

Figure 5. EWEB REC Obligations under budget hydro assumptions and better

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

450,000

500,000

MWh per year

EWEB Forecast REC Portfolio Supply and Demand

Wholesale Sales

Green-Power Sales

RPS Obligation AFTER Exempt Resources (None)

Annual REC Supply

Based on 90% of normal exempt hydro generation all years.

Only in the event that the Hynix facility reopens or a similarly sized facility locates in Eugene 

would EWEB experience a sustained annual RPS obligation. For this reason EWEB will

continue to maintain an inventory of stored RECs to allow for time to adapt should a new 

customer arrive. REC inventories above this level will be treated as surplus, and staff will seek 

to maximize their value with future sales. It would take an extremely large facility locating in 

Eugene to increase EWEB’s RPS REC obligation above the capability of EWEB’s existing 

portfolio. 
EWEB 2011 RPS Compliance Report Page 8 

Attachment 1

Summary of Oregon’s Renewable Portfolio Standard