Comment Log Display

Comments by 350 Bay Area on the July 9 CPUC/CEC/ARB/CAISO symposium
on meeting California’s 2030 GHG goals, focused on the transition
to renewable energy generation 
 
1the Pathways Analysis sponsored by CARB, CAISO, CPUC, and CEC and
conducted by  Energy + Environmental Economics (E3) should include
relevant cost savings to accurately reflect the costs of the early
deployment strategy compared to the other scenarios.

Specifically, the Pathways Project is designed to “evaluate the
feasibility and cost (emphasis added) of a range of greenhouse gas
reductions scenarios in California “.  The cost impact is
summarized on slide 18 of a previous presentation to CARB  of the
draft Pathways results (appended) and appears to show that the
early deployment scenario has dramatically higher incremental costs
by 2030 than the straight line or delayed deployment options. 
However, since the early deployment scenario (critically important
for rapid reductions in GHG emissions) would result in a more rapid
decrease of emissions of greenhouse gases and criteria pollutants
than the other scenarios, there would be real and quantifiable
health benefits with the early deployment scenario.  It is
misleading to fail to include those direct cost savings in the
analysis, especially when policymakers may rely on figures such as
slide 18 to conclude that early deployment is not economically
feasible.
  
The Pathways analysis considers costs from a range of perspectives,
not just that of the utilities, such as changes in consumer
vehicles and residential heating investments, as well as the impact
on household expenditures.  Therefore, it seems entirely reasonable
that it should also include well accepted estimates for savings
from health benefits, which are a direct result of the early
deployment intervention.  For example, as part of the Clean Power
Plan the EPA monetized the air pollution health co- benefits from
reductions in criteria pollutants.  This analysis was specific to
California and would provide a credible source for figures on the
benefits of reductions in Particulate Matter- 2.5 (
$360,000-$800,000 per ton in 2011$) and Nitrogen Oxides (
$11,000-$47,000 per ton in 2011$) (reference below).

1)the CPUC should be held accountable to meet their critical role
in reaching California's greenhouse gas emission reduction goals. 
 
A number of symposium presenters expressed concerns about
over-generation and curtailment in the future with the increasing
proportion of renewable resources on the grid, apparently assuming
over-generation and curtailment are inevitable.  However, Laura
Wisland from the Union of Concerned Scientists said during the
stakeholder panel that the UCS model shows that it is feasible to
use fast response storage and Demand Response to maintain system
flexibility and reliability, decreasing the use of gas generation
and avoiding curtailment and overgeneration.  The CPUC should
develop concrete plans to encourage investor owned utilities to
accelerate investments in such approaches to grid reliability,
especially given the decreasing cost of storage, the innovative
applications of demand response, the expense and GHG profile of gas
peaker plants, and the expense and opportunity cost of
curtailment.

Ed Randolph of the CPUC discussed the complexity caused by the
multiple current CPUC proceedings relevant to California's
transition to renewable energy, but did not suggest any practical
solutions.  The CPUC should propose how they plan to meet the
state’s goals with a more integrated process.   In addition to a
strategic approach to integrated planning, several suggestions from
the symposium could be considered, such as adding storage to the
renewable generation obtained for RPS procurements; permitting pump
storage to qualify as storage  (rather than current  requirement
for "new technology"); and  increasing the time horizon of the long
term procurement proceeding to 20 years.

see document plus Figure 18 in zip file attachment

reference:  US Environmental Protection Agency,  " regulatory
impact analysis for the proposed carbon guidelines for existing
power plants and emissions standards for modified and
reconstructive power plants" June 2014.  Table 4 –9 p. 4 – 27. 
Available at http://www2.epa.gov/sites/production/files/2014 –
06/documents/2014 0602 ria – clean – power – plan. Pdf