California SB 100: Interim Targets, SB 1020, and Penalties

California’s SB-100 requires that 100 percent of electricity sold to retail customers in the state come from renewable and zero-carbon sources by December 31, 2045. Signed in September 2018, the law also raised the state’s Renewables Portfolio Standard to 60 percent by 2030 and set escalating benchmarks along the way. A follow-up bill, SB 1020, added binding clean-energy targets for 2035 and 2040. Together the two laws bind every investor-owned utility, community choice aggregator, electric service provider, and publicly owned electric utility operating in California.

The Two Tracks Inside the Law

SB-100 works on two tracks, and confusing them leads to a lot of misreadings. The first is the Renewables Portfolio Standard, a hard procurement requirement that a growing share of retail electricity come from RPS-eligible sources: solar, wind, geothermal, biomass, biomethane, small hydroelectric (generally 30 megawatts or less), and fuel cells running on qualifying renewable fuel.1California Energy Commission. 2021 SB 100 Report and 60 Day Report Large hydroelectric dams and nuclear plants are explicitly excluded from that count.

The second track is the broader 100 percent clean-energy mandate for 2045, codified at Public Utilities Code section 454.53. It allows both RPS-eligible renewables and “zero-carbon resources” to count.2California Legislative Information. California Public Utilities Code 454.53 Zero-carbon resources has no formal statutory definition, but the joint agency reports have treated it as covering existing nuclear generation, large hydroelectric facilities, natural gas paired with 100 percent carbon capture, and clean hydrogen combustion. That flexibility was deliberate: the last stretch to 100 percent will likely require technologies that don’t fit the traditional renewables box.

Interim Targets Utilities Must Hit

SB-100 raised the RPS milestones set by earlier law. Retail sellers and publicly owned utilities must procure eligible renewable energy at the following minimums:

  • 44 percent of retail sales by December 31, 2024
  • 52 percent by December 31, 2027
  • 60 percent by December 31, 2030

The legislature also declared a goal of 50 percent renewables by December 31, 2026, which functions as a policy target rather than a hard procurement floor.3California Legislative Information. California Public Utilities Code 399.11 After 2030, the CPUC must set ongoing three-year compliance periods that keep retail sellers at no less than 60 percent RPS procurement.4California Legislative Information. California Public Utilities Code 399.15

What SB 1020 Added for 2035 and 2040

When SB-100 passed, it jumped from 60 percent renewables in 2030 to 100 percent clean energy in 2045 with nothing binding in between. The Clean Energy, Jobs, and Affordability Act of 2022 (SB 1020) amended section 454.53 to add two interim clean-energy benchmarks:

  • 90 percent of retail electricity sales from renewable and zero-carbon resources by December 31, 2035
  • 95 percent by December 31, 2040

These cover the full clean-energy mix, so nuclear, large hydro, and other zero-carbon sources count.2California Legislative Information. California Public Utilities Code 454.53 SB 1020 also extended the 100 percent clean-energy requirement to electricity procured by all state agencies.

Who Has to Comply

The law reaches every entity that sells electricity to California retail customers, split into two regulatory tracks.

“Retail sellers” include the investor-owned utilities (Pacific Gas and Electric, Southern California Edison, and San Diego Gas and Electric), community choice aggregators, and electric service providers. The CPUC establishes their compliance periods and procurement targets and enforces them through the Integrated Resource Planning process and Resource Adequacy program.4California Legislative Information. California Public Utilities Code 399.15

Local publicly owned electric utilities, such as the Los Angeles Department of Water and Power and the Sacramento Municipal Utility District, face the same percentage targets but answer to their own governing boards. The California Energy Commission sets their multiyear compliance periods and monitors their progress.5California Legislative Information. California Public Utilities Code 399.30 One carve-out matters: a publicly owned utility that already gets more than 40 percent of its retail sales from large hydroelectric generation is not required to procure more than its specified minimum of RPS-eligible renewables. That mainly protects Northern California utilities heavily reliant on existing hydro.

Penalties for Missing the Targets

The penalty for falling short of an RPS procurement requirement is $50 per Renewable Energy Credit of deficit, which equals $50 per megawatt-hour missed.6California Public Utilities Commission. 2025 California Renewables Portfolio Standard Annual Report For a utility with millions of megawatt-hours in annual sales, even a small percentage shortfall runs into millions of dollars. During the 2011–2013 compliance period, total penalties collected for non-compliance reached approximately $4.1 million.

Penalties can also apply to administrative violations. In the 2017–2020 compliance period, three retail sellers that met their procurement quantity but failed RPS contract and reporting requirements received revised penalties of $500 each, reflecting the administrative nature of the violation.6California Public Utilities Commission. 2025 California Renewables Portfolio Standard Annual Report

For publicly owned utilities, enforcement runs through the governing board and CEC reporting rather than direct CPUC fines. Public accountability, not a dollar penalty schedule, is the primary lever.

Oversight and the Quadrennial Report

Three agencies share implementation: the California Energy Commission, the California Public Utilities Commission, and the California Air Resources Board. They must submit a joint policy report to the legislature every four years, assessing progress and identifying obstacles, with participation from the California Independent System Operator, which runs the grid.7California Energy Commission. SB 100 Joint Agency Report

The first joint agency report, published in 2021, modeled several paths to 100 percent clean electricity and concluded that going from the 60 percent RPS floor to full clean electricity would add roughly 6 percent to total annual electricity system costs.7California Energy Commission. SB 100 Joint Agency Report The agencies also flagged grid reliability, land use, energy equity, and workforce development as areas needing deeper analysis in future reports.8State of California Energy Commission. 2021 SB 100 Joint Agency Report Summary

What It Means for Rates

The mandate has cost implications customers are already seeing. As of December 2025, California’s average residential electricity rate was 34.71 cents per kilowatt-hour, more than double the national average of 17.24 cents.9U.S. Energy Information Administration. Electric Power Monthly – Average Price of Electricity to Ultimate Customers by End-Use Sector Not all of that gap is renewable procurement; wildfire mitigation, transmission investment, and higher construction and labor costs also play roles. But the clean-energy buildout adds pressure, and the joint agencies have acknowledged that affordability and equity need more thorough treatment in future reports.

How SB-100 Fits With California’s Wider Climate Framework

SB-100 governs electricity, which accounts for roughly 16 percent of California’s greenhouse gas emissions. Governor Brown signed the bill the same day he issued Executive Order B-55-18, setting a statewide goal of carbon neutrality by 2045 and net-negative emissions after that.10State of California. Governor Brown Signs 100 Percent Clean Electricity Bill, Issues Order Setting New Carbon Neutrality Goal Cleaning up the grid is necessary for that broader goal but nowhere near sufficient on its own; transportation, buildings, and industry sit outside SB-100’s reach.