Comment Log Display

The Southern California Public Power Authority ("SCPPA")compliments
the  Staff on its effort to identify the 1990 total statewide
aggregated emissions level.  However, SCPPA urges the Board to
permit further adjustment of the 1990 total.  

SCPPA is particularly concerned that the 1990 total that is
presented for Board adoption may be understated due to an
understatement of the 1990 emissions associated with imported
electricity.  According to the Staff Report, electricity
generation emissions account for 26 percent, 110.6 MMTCO2e, of the
total 1990 emissions of 427 MMTCO2e.  Approximately a third of the
electricity generation emissions, 31 MMTCO2e, is associated with
"unspecified imports" for which the generating plant is unknown. 
That figure may be low by as much as 10-20 MMTCO2e. 

The figure for emissions associated with unspecified electricity
imports is based on region-specific emission factor assumptions
for the Pacific Northwest and the Pacific Southwest.  The Staff
relied on certain CEC assumptions.  SCPPA is concerned that those
assumptions may not accurately reflect the actual dispatch of
electricity from, particularly, the Pacific Northwest.  

SCPPA urges the Board to permit the 1990 figure for electricity
generation to continue to be refined both by specifically
identifying imports that have been heretofore classifed as
"unspecified" and by further examining the assumptions that the
Staff adopted from the CEC.   

Thank you for this opportunity to express SCPPA's concerns.