Comment Log Display

When considering the 2020 emission limit of 427 million metric tons
of carbon dioxide equivalent (MMTCO2E) of greenhouse gases in
conjunction with the Western Climate Initiative (WCI), will
emissions leakage be considered?  Specifically, BC Power, the
government-owned utility in British Columbia, has been in power
deficit for 10 of the past 11 years.  It makes up that deficit by
importing coal-fired power from Washington state and the province
of Alberta.  BC Power then sells California “green” hydropower
after backfilling their grid deficit with coal power. 

Will the ARB account for this form of electron laundering by
looking at the full life cycle emissions of the sources of power
imported into California?  How will the ARB attempt to account for
multiple sources of power generation within the Western
Interconnection?  Has ARB considered the cost impact of electricity
to California consumers if BC Power, or other providers of
electricity, are forced to purchase emissions allowances to fully
account for their electron laundering?