Comment Log Display

ETAC II. D.pp 4-6 
1) The document is silent on distributed renewable generation,
with the exception of solar PV.
2) A detailed discussion of the opportunities for landfill gas and
wastewater treatment plant digester gas fueled electrical systems
should be provided. The currently available biogas resources could
provide California with approximately 950 MW of renewable
electricity.  The Plan should stress that the technology is fully
developed. These technologies have been stymied for  many the of
same reasons discussed in the ETAAC Chapter 6 Agricultural Sector,
Section II-A Manure to Energy Facilities staring on  page 6-3. 
There should be a discussion of co-digestion system for garbage
and/or green waste, along with wastewater treatment plant sludge.

Scoping Plan II B. 3 pg 21
1) This section refers to existing CEC and CPUC energy incentive
programs.  These programs do not provide adequate incentives for
energy recovery systems that produce power or electricity.  There
are many examples of systems that do not fit the existing paradigm
of energy conservation or self generation incentive programs,
including: In-conduit hydroelectric energy recovery systems in
water system piping; wastewater systems; and liquid and pressure
reduction systems that produce power from utility and industrial
gas piping systems. Additionally, there are not adequate
incentives for creative energy conservation projects. 
2) The disincentive for customers who use self-generated renewable
electricity is that they can not receive the CPUC Public Goods
supported energy efficiency incentives or grants. By allowing
renewable energy users to participate in these programs would
increase the availability and use of renewable energy. 

Scoping Plan II B. 3 pg 25-45
1) Propane vehicle fuel systems did not receive the tax incentives
from the air districts that the CNG and LNG received. This
technology still exists and can service a large portion of the
gasoline market that CNG has had trouble addressing due to its
limited range and the access to CNG refueling stations.
2) Solar hot water systems are generally twice to three times more
efficient than solar-electric systems.  They are not covered in
this section.  The technology and its service network have been in
place since 1978. 
3) The plan is silent on landfill gas and wastewater digester gas,
as well as the developing co-digestion digester gas. Only the
developing agricultural manure methane producing systems are
discussed.  
4) Suggest adding the following to this table: 
a. Renewable Energy Self Generation: including biogas, wind,
in-conduit hydro and pressure reduction energy recovery stations
for Self Generation applications
b. Renewable Energy for Sale: with the CPUC’s providing the MPR
for the energy sold, plus any associated costs to totally mitigate
the carbon foot print for the fossil fuel avoided. 
c. Combined Heat and Power:  New system’s total efficiency should
exceed the delivered electrical efficiency of the State’s
electrical resources at the time of approval of interconnection.
d. Energy Recovery systems.  See A: above.   Additionally, there
are many options for heat recovery from processes that could
become cost effective once the full cost of mitigating the use a
fossil fuel (nature gas) is associated with the use of the fuel
though increased costs of the fuel or through incentives to
conserve.
5) The Stationary Internal Combustion Engine Electrification
section needs clarification.   Many of these engines producing
power have a specific purpose that can not be replaced by an
electric motor. Many others, when transmission losses are taken
into account, are producing power more efficiently than utility
supplied electricity.
6) Carbon offsets should also be provided for certifiable
temporary measures and installations.  These could be traded to
temporary uses of fossil fuels and electricity.  That is, the
credits generated by temporary shutting down a boiler for
rehabilitation of a refinery process could be traded to the Circus
who needs to heat, light and ventilate and their tents for the few
months they are in town. 

Scoping Plan and ETAC:
1) “Maximize economic benefits…”  Combined Heat and Power (CHP),
self generation, renewable energy (including all biogas systems)
and power recovery systems can proliferate, as CHP did in the
1980s driven by the economic benefits provided by the CPUC, if the
CPUC designs the rates and provides electricity buyback contracts
that encourage their development. The MPR should either be
substituted with a new system similar to the used in the 1980’s
Stand Offer Contracts, or the MPR needs to take into account the
full cost of fossil fuel carbon mitigation.  The investor owned
utilities should not be allowed to negotiate prices lower than
that set by the CPUC. Currently the utilities are encouraged to
obtain a rate lower than the MPR from the renewable generator.
Consequently, they have turned away many renewable electricity
contract offered at the MPR.
2) The CPUC should redesign the electric rate structures to
encourage conservation and to account for electricity’s carbon
foot print.