Comment Log Display

From: Hendry, James 
Sent: Wednesday, September 22, 2010 11:44 AM
To: 'Collord, Gary@ARB'
Cc: Broome, Bart; Ramirez, Manuel
Subject: CCSF Comment on RES language -- Suggested change

 

Gary – Sorry for the late notice, but in reviewing the ISOR, we
are
concerned that the RES standard could hold the City and County of
San Francisco (CCSF) to a RES greater than the 33% that all other
utilities are responsible for, and could do so even prior to 2020.

 The proposed language is inconsistent with both SB722 and AB32.

 

The 67% language contained in SB722 was designed to be
self-enforcing.  As long as CCSF was greater than 67% hydro, then
the remaining energy needs would be met by RPS resources.  Should
CCSF fall below the 67% threshold, than CCSF would be subject to
the same requirements as any other utility

 

Under the proposed regulations as explained in the ISOR, however,
CCSF could face a RES obligation that “could be less than, or in
excess of, the RES percentages in Table 1” (ISOR p. VIII-7).  For
example, if in 2012, there was a significant outage of CCSF’s
hydro
generation and it fell to only 60% of our requirements, CCSF would
be obligated to meet a 40% RES requirement in 2012, while all
other
utilities (all of which have significantly higher GHG-emissions)
are only subject to a 20% RES requirement.  

 

This does not comport with either the intent of SB722 or the
requirements of AB32.  As noted above, the intent of SB722 was
that
it would be a self-enforcing alternative that would not apply if
CCSF otherwise met the requirements of the RPS (now REC) standard.

.

 

Under the proposed regulations, CCSF, with a GHG emission level
much lower than other utilities would be held to a much higher
standard than any other utility in the state.  We think you agree
that this is a problem.

 

The attached language fixes this problem.

 

Please feel free to contact me at (415) 867-9596 or Bart Broome at
(415) 554-0706 if you have any questions