First Name | Edward |
---|---|
Last Name | Mainland |
Email Address | emainland@comcast.net |
Affiliation | Sierra Club California |
Subject | Sierra Club Comment on Renewables Portfolio Standard |
Comment | COMMENTS ON AB 32 PROPOSED SCOPING PLAN, SUBMITTED BY SIERRA CLUB CALIFORNIA, November 19, 2008 4. Renewables Portfolio Standard (p. 44) • Sierra Club is pleased to see CARB’s recommendation for a 33% Renewable Portfolio Standard (RPS) for electricity providers. This forward-thinking measure should be quickly given the force of law for all utilities, either by regulatory action or by legislation. On July 24, 2008, Sierra Club presented the Governor and the legislature’s leadership with a 14-point plan to reform and supplement RPS. • We appreciate the mention of “broad-based participation from many parties and the removal of barriers.” We look forward to more consideration of the environmental and consumer points of view. • Although the Plan mentions “Community Energy” and “municipal utility operations,” there is no mention of Community Choice Aggregation (CCA), a specific authority under California law (AB 117, Migden). CCA offers large potential for local governments to move aggressively toward meeting or exceeding the state’s mandated Renewable Portfolio Standards (RPS). Over 40 cities and counties in the state have performed feasibility studies financed by the California Energy Commission and the U.S. Department of Energy, with over two dozen jurisdictions in advanced stages of planning for actual implementation. Marin County, Oakland, Berkeley and Emeryville, as well as San Francisco have either established or are considering a target of 50% or more renewables for all customers within their service region by 2017. When achieved, such targets represent the single easiest way for municipalities to comply locally with whatever AB 32 stipulations may be imposed. Sierra Club urges ARB to make CCA a central part of its GHG reduction strategy in the near and medium term. • Sierra Club is very pleased with the inclusion of the option of “a Feed-In Tariff for all RPS-eligible renewable energy facilities,” but questions the phrase “up to 20 megawatts in size.” We favor implementation of feed-in tariffs at once for all sizes of facilities. Feed-In Tariffs (FiTs) are efficient tools for speeding adoption of renewable electricity generation and stabilizing market prices of new technologies. Already used in more than 37 countries, and under consideration in Michigan, Minnesota, Illinois and Rhode Island, FiTs establish a price for renewables — guaranteed for 20 years or more — based on the cost of producing that electricity plus a fair profit. These rates usually have a modest impact on customer bills compared to conventionally generated electricity. (In Germany, for example, the FiT cost to consumers equals the price of a loaf of bread per month.) FiTs allow manufacturers and renewable project developers to predict demand, and to invest with confidence. California should model its FiTs on those programs that have achieved significant growth of renewables. A FiT in California should be tied to meeting the state’s goals for renewables. CARB should also recommend restructuring state law to allow more favorable renewable energy price structures. • California Energy Commission's workshops on Feed-In Tariffs need to offer much more aggressive and comprehensive options, and CARB must prod CEC to do this. • As the California Energy Commission’s recommended in its 2007 Integrated Energy Policy Report, any carbon trading system should reduce allowances according to an appropriate evaluation of the effects of the renewable portfolio standard — in order to avoid oversupply of allowances. • CARB should consider and address the full life cycle of emissions whenever possible. Currently, there appears to be an inconsistency across sectors. Transportation fuels take a full life cycle approach, but the energy sources for electric generation and end-use natural gas consumption do not. Unfortunately, the CPUC’s interpretation of SB 1368 would allow about five million tons of GHG per year per Liquefied Natural Gas (LNG) terminal to go into the atmosphere without being “counted” as part of the state’s carbon emissions, if these terminals are constructed. This is not an abstract issue, as we already face the likelihood of imported LNG increasing the carbon footprint of pipeline natural gas from Texas and Mexico. That is a loophole that should and must be closed: five million tons of GHG per year is roughly equivalent to the emissions of one million cars. • Sierra Club urges CARB to ensure that electric power generators be held to an increasingly stringent carbon standard, and that the carbon standard be applied to all generators, whether under contract or utility owned, and to all types of retail sellers of electricity within the state. • Sierra Club believes CARB’s target of reducing coal generation 40%, or 13,000 gigawatt-hours, by 2020 is an achievable goal, provided that utility companies are held to the renewable energy and efficiency targets. • Industrial boilers, oil refineries and glass manufacturing represent excellent opportunities to recover waste heat for electric generation and other purposes. |
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Date and Time Comment Was Submitted | 2008-11-19 18:42:14 |
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