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Comment 13 for Energy Comments for the GHG Scoping Plan (sp-energy-ws) - 1st Workshop.
First Name: Edward
Last Name: Mainland
Email Address: emainland@comcast.net
Affiliation:
Subject: Electricity Sector -- 33%, CCA, FiT, Allowances
Comment:
• 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.
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Date and Time Comment Was Submitted: 2008-07-30 15:58:15
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