Comment Log Display

 

August 5, 2013

Mr. Mike Tollstrup
California Air Resources Board
State Environmental Protection Agency
Sacramento, CA 95814

RE:       Comments on the California Air Resources Board (CARB) 
2013 Update to AB 32 Scoping Plan 

Dear Mr. Tollstrup:
The Center for Energy Efficiency and Renewable Technologies (CEERT)
appreciates the opportunity to provide these comments regarding the
California Air Resources Board’s (ARB) 2013 Update to the AB 32
Scoping Plan. The 2013 AB 32 Scoping Plan begins to set the stage
for the post-2020 greenhouse gas (GHG) reduction plan for
California. 
In order to accelerate the implementation of strategies to achieve
targets of the previous scoping plan, and to set California on a
course to achieve the much deeper reductions in GHG emissions
needed by 2050, CEERT recommends the following six actions: 

1)	Methane, black carbon and other short-lived pollutants.  AB 32
called for CARB to develop a plan to reduce black carbon and other
short-lived climate pollutants (SLCPs). These actions, which could
have an immediate effect in reducing global warming and improving
air quality, have not been developed or publicly presented. CARB
should work with local air pollution districts to define and
implement a regulatory plan to reduce emissions of SLCPs, which
would complement the state’s plan for reducing emissions of CO2.
This plan should include:
a.	Appointing a scientific advisory panel on SLCPs to ensure
accurate metrics and assumptions upon which to base SLCP-reducing
measures. Independent scientific experts from Scripps, Stanford,
the University of California , and around the world are conducting
crucial scientific research and applied studies, which should guide
CARB in developing its regulatory strategy for SLCPs. 

b.	Work with air pollution control districts to develop, adopt, and
enforce rules on stationary and fugitive sources of methane and
black carbon, and enforce control measures and monitoring practices
to reduce SLCPs, including the following: 
i.	Designating methane as an ozone precursor and measuring
emissions at oil and gas operations.
ii.	Installing methane digesters and capture systems and collecting
slash and other debris from forest and agricultural waste. 
iii.	Further reducing emissions from existing on and off road
diesels; requiring pellet- or catalyst-equipped burning on stoves
and fireplaces; and accelerate the phase out of agricultural
burning, diverting these wastes to cleaner biomass energy plants. 
iv.	Working with CalRecycle to implement regulations to greatly
reduce landfill methane emissions by limiting leakage, capturing
and converting methane into near zero distributed clean energy
uses, and reducing the amount of organic material entering
landfills.
v.	Prohibiting HCF-134a leaks, requiring reprocessing, switching
refrigerants, and capturing “banked” gases from automotive and
appliance air conditioning and refrigeration. 

The following graph from the UNEP 2011 Assessment (Drew Shindell et
al) shows the importance of SCLP reductions for lessening global
warming in the near term.


2)	The need to minimize GHG emission when replacing electric energy
previously provided by San Onofre Nuclear Generating Station
(SONGS). The permanent shut down of SONGS, when combined with the
pending retirement of once through cooling plants on the coast,
will result in substantial need for replacement power.  There is
also significant uncertainty regarding the long term operation of
Diablo Canyon nuclear plant near San Luis Obispo, and contingency
planning for its possible retirement should begin now. 

In these circumstances, every effort should be made to ensure that
any “replacement resources” procured by the utilities minimize or
reduce GHG emissions. An important distinction should be made
between replacement of local capacity needs and energy previously
provided by retiring power plants.  Local capacity provides the
ability to  provide local grid support during rare emergencies. 
Facilities providing replacement energy need not all be local and,
when producing energy, should have low GHG emissions (from zero and
near-zero to significant GHG emissions).  For example, to replace
SONGS, the local capacity requirements are likely to be in the 300
MW range, which requires quick start-up in key locations.  SONGS
energy replacement would likely be in the 2,000 MW range from any
location. 

It is important that the portfolio of sources of replacement power
not result in significant increases in GHG emissions or a
substantial increase in California’s already significant dependence
on natural gas, which currently provides more than 60% of the
state’s electricity in net dependable capacity. This is essential,
given the wide range of uncertainty regarding the actual life cycle
emissions of natural gas, and the climate forcing potential of
methane.   

Demand response, energy efficiency, clean distributed generation,
renewables, transmission expansions, and sharing resources with
municipal utilities should be the primary sources of replacement
power.  Advanced, high efficiency, quick start, fast ramp natural
gas plants should provide needed capacity but be designed and
allowed to operate only when preferred resources are not available.


3)	Setting Medium and Long Term Clean Energy Targets. California is
well on its way to producing 33% of its energy from wind, solar
thermal, photovoltaic, and geothermal renewable energy by 2020.
However, California must not lose momentum in reducing dependence
on fossil fuels after the 2020 deadline of AB 32.  We must evaluate
the successes and failures of the RPS procurement system and
determine what changes are needed to move toward greater reliance
on energy efficiency, renewables, and other low-carbon resources
and technologies.  Recent analyses by grid operators and energy
agencies suggest that increasing penetration of renewables must be
undertaken with greater attention to load balancing, geographic
diversity, and a diverse renewable portfolio. Out of state wind and
solar and Imperial Valley geothermal can make large contributions
to system balancing, given the geographic diversity of their
output. California must look regionally in order to balance the
system with least emissions.

AB 177 by Assembly Member Manuel Perez is currently pending before
the State Legislature and would establish an integrated planning
and procurement policy for the electric sector, based on the
simultaneous achievement of renewables, reliability, and GHG goals,
with an interim renewables target of 51% by 2030 and a long term
GHG target for 2050, as determined by the ARB. 

In order to provide long term direction to California’s energy
infrastructure toward sustained, orderly reductions in GHG
emissions, utilities should be required to achieve a target of 51%
of its electricity from renewable or zero carbon energy sources by
2030. CARB, working with the CEC, CPUC, and CAISO, should conduct
analyses to determine appropriate goals for 2040 and 2050. These
goals must be in place soon in order to plan for and achieve them.

4)	Energy efficiency and Demand Response.  We must greatly expand
targeted energy efficiency, demand response, and clean distributed
generation as the core strategy for meeting the load balancing
needs of California’s electric grid. If California is to
successfully achieve greater reductions in greenhouse gas emissions
and sustained, orderly expansion of clean energy, we must tear down
the silos of energy planning and procurement and recognize the
linkages between greenhouse gas emissions, renewables, reliability,
and affordability, and adopt policies and planning to achieve these
goals simultaneously. 

5)	Extending energy efficiency measures through building/appliance
programs.. California should consider setting up an Energy
Efficiency Utility as a state-chartered, non-profit corporation, as
Vermont and Delaware have done, in order to achieve higher levels
of energy savings in every region of the state at lower cost. This
corporation could be organized by county, building on new/existing
Regional Energy Efficiency Networks such as CCSE in San Diego.
Similarly, Sonoma County is actively considering setting up a
non-profit corporation to pursue EE savings in the region. 

Zero or near-zero carbon distributed generation needs a policy
framework to guide evolution of intelligent local networks. Such a
framework could start with: a) principles for Open Access to the
distribution system; and b) rate restructuring and time of use
pricing, with a distribution charge to pay for upgrading and
maintaining more capable local grids.  An all-technology feed-in
tariff tied to GHG reductions should also be considered.
6)	Reducing Existing CO2.  California should begin developing plans
and mechanisms for reducing and ultimately eliminating carbon
dioxide from the ambient air and water.