| Comment | From: Hendry, James
Sent: Wednesday, September 22, 2010 11:44 AM
To: 'Collord, Gary@ARB'
Cc: Broome, Bart; Ramirez, Manuel
Subject: CCSF Comment on RES language -- Suggested change
Gary – Sorry for the late notice, but in reviewing the ISOR, we
are
concerned that the RES standard could hold the City and County of
San Francisco (CCSF) to a RES greater than the 33% that all other
utilities are responsible for, and could do so even prior to 2020.
The proposed language is inconsistent with both SB722 and AB32.
The 67% language contained in SB722 was designed to be
self-enforcing. As long as CCSF was greater than 67% hydro, then
the remaining energy needs would be met by RPS resources. Should
CCSF fall below the 67% threshold, than CCSF would be subject to
the same requirements as any other utility
Under the proposed regulations as explained in the ISOR, however,
CCSF could face a RES obligation that “could be less than, or in
excess of, the RES percentages in Table 1” (ISOR p. VIII-7). For
example, if in 2012, there was a significant outage of CCSF’s
hydro
generation and it fell to only 60% of our requirements, CCSF would
be obligated to meet a 40% RES requirement in 2012, while all
other
utilities (all of which have significantly higher GHG-emissions)
are only subject to a 20% RES requirement.
This does not comport with either the intent of SB722 or the
requirements of AB32. As noted above, the intent of SB722 was
that
it would be a self-enforcing alternative that would not apply if
CCSF otherwise met the requirements of the RPS (now REC) standard.
.
Under the proposed regulations, CCSF, with a GHG emission level
much lower than other utilities would be held to a much higher
standard than any other utility in the state. We think you agree
that this is a problem.
The attached language fixes this problem.
Please feel free to contact me at (415) 867-9596 or Bart Broome at
(415) 554-0706 if you have any questions
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