Comment Log Display

Sempra Generation appreciates this opportunity to provide comments
on CARB’s Proposed Regulation for a California Renewable Energy
Standard, dated June 2010.   Sempra Generation is an owner and
developer of renewable and fossil energy resources principally
serving markets in the southwest United States.   

The Renewable Energy Standard (“RES”) regulation at §97011
subsection (a) calls for the Executive Officer, in coordination
with the CEC, CPUC and CAISO, to conduct three reviews of the RES
program to improve implementation progress.  These reviews are to
consider, among other things, the feasibility and cost of advances
in renewable technology, impacts on electric rates and economic
growth, and to propose possible compliance interval adjustments to
reduce costs and increase program effectiveness.   

The CARB should carefully consider the impact of program changes
on new renewable and infrastructure development.  Certainty in the
program elements and compliance provides developers with the
stability necessary to make investments and move renewable projects
forward.  The potential to change key program elements such as
compliance intervals or to account for unproven non-commercial
technologies could have a chilling effect on development and be
counter-productive to achieving the RES objectives.  Sempra
Generation recommends that the three program reviews by December 31
of 2013, 2016 and 2018, be replaced by a single review for the
purpose of proposing program amendments by December 31, 2016.  This
balances the need for program stability with the opportunity to
alter program elements to achieve specific goals.