Comment Log Display

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.