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Comment 202 for General Comments for the GHG Scoping Plan (sp-general-ws) - 1st Workshop.


First Name: Virginia
Last Name: Nicols
Email Address: vnicols@ecomotion.us
Affiliation:

Subject: Comments on the CARB Climate Change Draft Scoping Plan
Comment:
 
August 1, 2008

Dear CARB Officials:
Thanks so much for the opportunity to provide written comments to
the Climate Change Scoping Plan Draft report. Speaking on behalf
of the City of Santa Monica’s Solar Santa Monica and its Advisory
Board members in particular, we salute your efforts to date and
offer the following comments in the spirit of enhancement.

The Santa Monica Context

Solar Santa Monica fully supports AB 32 and its successful
implementation. Just as the State of California has set ambitious
– seemingly impossible “stretch goals” for climate change
mitigation -- the City of Santa Monica has also taken a leadership
position:
•	By 2015, Santa Monica intends to cut overall city GHG emissions
to a level 15% below 1990 levels. By the same date, Santa Monica
intends to cut City uses and GHG contributions by 20% below 1990
levels.
•	Through the Community Energy Independence Program and Solar
Santa Monica, the City intends to be a “net zero electricity
importer” by 2020. This means that enough power will be conserved
and locally generated to completely offset traditional sources.

Santa Monica realizes that State initiatives are essential. One
thing is abundantly clear: Without effective state and national
leadership, Santa Monica will be unable to reach its goals.

General Comments on the Scoping Plan

Mitigating emissions and stabilizing the climate is an enormous
task. Again, we salute your efforts and stand ready and willing to
support your works in the months and years to come. 
The 169 MMTCO2E reduction target is daunting. We’re pleased to see
that energy efficiency and renewable energy technologies – mostly
in the form of the RPS – play such a major role.
However, we are surprised that solar energy, particularly
photovoltaic electricity production, seems to have such a small
role. The plan cites the existing Million Solar Roofs initiative
as making a 2.1 MMT contribution, and that if the goal for the
program is raised from 3,000 MW to 5,000 MW that this will result
in another “up to 1 MMT” of GHG reductions. A few points:
	 
First, it appears that the CSI is far short of its goals in terms
of installed capacity. The CSI  is charged with achieving 3000 MW
of production by 2017.  In 2008, the CSI administrators estimate
that the program will add 100MW total for the year.  With CSI’s
decreasing incentives and limited applicability, California is
likely to fall far short of the 3,000 MW goals with the current
program design.
	
While increasing the goal is appealing, it may be very unrealistic
given the current CSI model. If we can’t reach 3,000 MW with the
current model (and the incentives are decreasing) how will we ever
attain 5,000 MW? (This same issue surrounds the RPS requirement:
How will we get to 33% by 2030 when we can’t reach 20% by 2010?)

Under current guidelines, the residential distributed generation
incented by the CSI does not count toward the utilities' RPS
targets.

Fourth, there is a major flaw in the CSI.  Because it is a net
metering program, it excludes all multi-tenant properties with
individually metered units and excludes all properties that do not
use much electricity. Given California’s net energy metering rules,
and Santa Monica’s preponderance of multi-unit apartments and
commercial buildings, major sectors are “boxed out” of the CSI.
With over 40,000 apartment units – ( and only 8,000 single family
homes) – the CSI is not available to a major proportion of the
building stock. Without modifications to the solar rules, Santa
Monica will not attain its goals for GHG reductions and energy
sustainability.

Our Specific Suggested Addition

A striking feature of the Scoping Plan is the limited role played
by solar. Imagine that less that only a percentage point or two of
the 169 MMTCO2E reduction goal is expected to be fulfilled by
solar. Given Southern California’s abundant sunshine and major air
conditioning demand, solar can play a far greater role and make a
far greater contribution. Consider the following:

The California Solar Initiative – despite its wonderful intent and
incremental success – appears to be falling well short of its
goals. While reservations dominate the activity, and result in
drops in the “degressive” incentive structure, there have been
relatively few installations. With incentives stepping down, and
federal tax credits in jeopardy, and shortages of panels on the
market, the solar future in California is in jeopardy. Clearly we
need a more aggressive solar strategy.
Germany’s feed-in tariff, in stark contrast, has resulted in that
country’s quick rise to solar prominence.  The tariff allows
anyone – from homeowner, to commercial property owner, farmer,
church, etc. – to sell the output of a solar system at a clearly
profitable price. Last year, in Germany, photovoltaics provided
over 1,000 MW of new electric capacity, while California installed
less than 100 MW. Despite average “insolation” of 3.5 hours a day –
like Fairbanks, Alaska – Germany’s incentive program spurred its
renewable energy industry. Over 55,000 German workers are now
researching and making and selling solar technologies throughout
Germany, Europe, and around the world.  California’s average
“insolation” is greater than Germany’s and therefore would require
a lower (less subsidized) tariff.

For California to increase its GHG contribution from solar systems
– both solar photovoltaics and solar thermal systems – there needs
to be a new and more aggressive model. The feed-in tariff provides
such value to the global community: We need and want solar, so
let’s adopt a working model. We urge that the feed-in tariff
mechanism – complete with clearly profitable pricing – be included
in the California Air Resources Board strategy.

Finally, introducing an omnibus feed-in tariff for renewable has
proven to be a challenging legislative pursuit. Various bills have
been promoted to bring this mechanism to California. However, the
very minor feed in tariff programs that are in place in California
are priced so low that they will not result in significant new
solar projects. 

Providing a first step that squarely addresses Santa Monica’s
housing stock is logical: Solar Sana Monica asks that the final
CARB report include and endorse a solar feed-in tariff that
requires utilities to purchase all power generated by PV systems
on all multi-metered buildings at a price that will cover the
system owner’s costs plus a reasonable profit. Later this can be
broadened to cover a) other renewable energy technologies, and b)
t the application of the feed-in tariff to other categories of
solar applications (including other building and non-building
categories).

Therefore, given Santa Monica’s experience with currently
available renewable energy programs, and our general comments to
the plan, we present a specific suggestion, namely, that
California adopt a feed-in tariff for renewable energy resources.
Just as Germany, Spain, Italy, South Korea and others have done,
we urge CARB to include such a mechanism in the final plan.
Feed-in tariffs work… and are a strategy that will help you reach
your goals while assuring a safe and sustainable energy future for
California.

Thank you again for the opportunity to submit these comments.
Sincerely and for the Solar Santa Monica Advisory Board,

Ted Flanigan, President of EcoMotion
Solar Santa Monica Facilitator

Susan Munves
Energy and Green Building Program Administrator
 

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Date and Time Comment Was Submitted: 2008-08-01 15:14:47



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