Comment Log Display

• We are pleased to see CARB’s recommendation for a 33% Renewables
Portfolio Standard for electricity providers. This
forward-thinking measure should be quickly be given the force of
law for all utilities, either by regulatory action or by
legislative enactment, or both. 
• Community Choice Aggregation (CCA) allows city and county
governments to pool the electricity-buying power of all local
customers, which could help meet (or even exceed) the 33%
renewable energy level. CCAs in advanced development stages, such
as Marin County and San Francisco, include 51% renewable
requirements in their plans.  CCA is one of the most powerful GHG
reduction measures available to cities and counties to comply with
their responsibilities under AB 32.  CARB’s scoping plan should
spell out CCA authority as a key tool provided under California
law (AB 117, Migden) that grants local governments full power in
planning for their energy supply.  
• CARB should also recommend restructuring state law to allow
energy price structures that are more favorable to renewable
energy, such as feed-in tariffs, which ensure full compensation
for renewable energy costs, plus a fair rate of profit. 
 • Feed-in Tariffs (FiTs) need explicit backing in CARB’s plan.
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.  
• We support and remind CARB of the California Energy Commission’s
recommendation in the 2007 Integrated Energy Policy Report that any
carbon trading system reduce allowances according to an appropriate
evaluation of the effects of the renewable portfolio standard — in
order to avoid over-supply of allowances.