Comment Log Display

Re:	Comments of the California State University System on the May
1, 2013 proposal to change the Cap and Trade Program. 

We have reviewed the Staff proposal and also had the pleasure of
meeting with the Staff after the May 1, 2013 meeting. We offer the
following comments.  

Credits for Universities

In response to ARB staff request to provide evidence of CSU
commitment to energy efficiency and the environment, following is a
summary of activities and achievement ss over the past decade.

The CSU system has invested heavily in CHP and other programs to
reduce GHG emissions. In the last 10 years, the CSU system has
devoted $150M to reduce energy use, build new CHP facilities,
construct new renewables facilities and retire ozone-depleting
substances. Over the last 37 years, CSU has reduced systemwide
energy use intensity by 50% and has the lowest Carbon footprint of
any public or private institution in the state at 437,000 Metric
Tonnes. Our current AB 32, 1990 target is 337,000 Metric tonnes and
includes four new campuses.

A San Jose State University, the campus has invested in Monitoring
Based Commissioning (MBCx) projects resulting in improved
operational efficiencies reducing energy consumption by
approximately 20 percent.

At San Diego State University the campus has capitalized on energy
efficiency and installed 700kW in photovoltaic systems offsetting
the impacts of more than 1M gsf in needed classroom and facility
space to accommodate enrollment growth.

CSU Channel Islands is a relatively new campus but has added new
chiller plant using waste heat to chill buildings.

CSU Campus Energy Initiatives and Programs

CSU campuses provide particularly strong evidence of applied
research programs in energy-related fields.

California State Polytechnic University, San Luis Obispo (250kW PV,
500kW cogen) (Cal Poly SLO).  Cal Poly SLO offers one of the best
known and highest ranked  Electric Power Programs in the nation.
The university has a rich history of applied research in electric
power, energy engineering, solar systems, alternative fuel and
electric vehicle development, and is a well-established leader in
undergraduate engineering education in these area.  

CSU Chico (436kW PV) has an active Environmental Studies and
Sustainability curriculum, including a professional Master’s degree
in Environmental Sciences. 

Humboldt State University (750kW Cogen) is home to the Schatz
Energy Research Center which serves the rural north coast region to
provide model energy systems and projects as well as energy
education.  

CSU Long Beach’s (635kW PV) Center for Energy and Environmental
Research in the College of Engineering is a leader in development
of wind powered energy advances and works closely with urban
transportation initiatives.  

CSU East Bay’s (1MW PV 1.4MW Fuel Cell) Environmental Studies
program has developed a model Energy and Environmental Studies
curriculum, initiated the installation and monitoring of the 1MW
campus photovoltaic systems, conducted many faculty-guided
student-based studies of energy efficiency and renewable energy
potential at CSU and in the surrounding communities, and the
environmental implications thereof.  

CSU Fresno (1.4MW PV) operates the Center for Irrigation Technology
and the California Water Institute, both key to understanding and
mitigating the water and energy uses of the state’s agribusinesses.
CSU Sacramento has created a Center for Micro Grid Development that
is a national model, and is leading the region in terms of product
testing of automated metering systems.  

The CSU Sacramento (450 kBTU Solar hot water, 436kW PV) Center for
Micro Grid Development provides practical solutions for
stakeholders in industry, utilities, and the public sector. Through
the excellent relationship that CSU Sacramento has with the City of
Sacramento, community engagement and outreach is emphasized to
demonstrate the benefits to consumers from every sector of our
society. 

San Jose State University (4.5MW Cogen) has created a Center for
Energy Management and provides leadership in a number of
energy-related areas, including energy efficiency technology such
as next generation battery storage materials. 

CSU Northridge (800kW solar, 1.4 MW Fuel Cell) has been at the
forefront of energy research and has built a strong portfolio in
distributed energy, including fuel cells, micro turbines, and solar
photovoltaic systems. 

San Diego State University (700kW PV, 14MW Cogen) researchers are
working on a cognitive home management system through funding from
the California Energy Commission. The project focuses on
residential home energy management and in particular on the
development of smart meters and non-parametric embedded controllers
for home demand response. 

California State Polytechnic University, Pomona (Cal Poly Pomona)
(700kW PV) is conducting research on Micro Grid technologies and
cyber security through the Center for Information Assurance.  

These are just a few of many exemplary stewards of applied
research, education, and services entities within the CSU that are
very productive, quality-oriented enterprises, and which will
support Micro Grid related applied research projects.

CSU submits that providing allowances to universities is a
worthwhile process. This allows CSU to continue its program of
operating its existing CHP units and investing in energy
efficiency.    

But For CHP

It has been CSU’s understanding that if a CHP facility became
subject to Cap &Trade because of its decision to install
cogeneration, increasing it emissions beyond the 25,000 Metric
Tonne threshold, ARB was going to capture only the emissions
required to serve the thermal load of the operation. Additionally,
a test was to be developed to exclude campuses from Cap &Trade
where a facility would not be subject to those obligations “but
for” the installation of cogeneration. The Staff’s program differs
in this regard as they confirmed only a few CHP facilities would be
exempted under the ARB concept, which includes both thermal and
electrical emissions. CSU calculated that the formula proposed by
the Staff does not work for any generator 11mw or greater. At May
1, 2013 hearing, ARB staff confirmed CSU’s assumptions.    

CSU suggests that, ARB exclude from the formula CHP emissions
generated to create electricity. Alternatively, CSU requests ARB
consider crediting the cogenerator with the emissions from its
facility that the utilities would have had to generate “but for”
the existence of the cogenerator.      

Legacy Contracts (Qualified Facilities ‘QF’)

CSU understands that the staff’s concept of legacy contracts does
not include any QF who sells power to a utility and seeks to rely
upon negotiation to address Local Distribution Company (LDC) – QF
contract issues. CSU urges the ARB to preserve the regulatory
integrity of the standard offer contracts established circa 1982,
and allow the remaining legacy QF contracts to continue
unencumbered by new regulation until their original contract
expiration on or about 2018. 

We request that ARB provide for emission allowances for any QF that
is not getting allowances from the LDC’s. This would be applicable
to any QF that was operating prior to the adoption of the later of
(i) the QF settlement or (ii) the approval of the Cap &Trade
regulations in December of 2011. This date was selected because
until those regulations were finalized and adopted, the system
could be changed.   

Definition of Facility

We have previously raised our concern regarding the definition of
‘facility’ with staff and believe it is applicable to any CHP
facility. The CSU believes a more comprehensive definition is
necessary for the following reason. Under the current definition of
‘facility’, a campus which has a CHP facility as well as other
smaller uses not connected to the CHP must still buy emission
credits for all uses within the legal limits of the property.     
Ultimately, this definition will result in CHP owners/operators
paying more to offset emissions for the non-CHP uses than would
others without CHP.   

Our recommendation is that the definition be changed to exclude for
CHP ‘facilities’ any small, residential or commercial core use
buildings not served by the CHP application.     This will resolve
any unintended disincentives for CHP that would arise from the use
of the current definition.