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Comment 19 for 2022 Scoping Plan Update - Electricity Sector Technical Workshop (sp22-electricity-ws) - 1st Workshop.
First Name: Claire
Last Name: Broome
Email Address: cvbroome@gmail.com
Affiliation: 350 Bay Area
Subject: Assure information available to optimize Distributed Energy Resources
Comment:
350 Bay Area appreciates the insightful and broad-ranging presentations and discussions during the November 2nd Electricity Sector Technical Workshop. A strategic approach to the electricity sector is a foundational necessity for meeting California clean energy targets as rapidly as possible. DER need to be optimized in system modeling: The CEC in their workshop presentation acknowledged that demand flexibility is a potentially large resource for savings in the California energy sector. Current modeling approaches such as RESOLVE do not distinguish between utility solar on the transmission grid and on the distribution grid, limiting the ability to realize the savings from demand flexibility and to accurately assess future transmission needs. (Behind the meter PV resources are modeled at a pre-determined amount.) Modeling should be able to optimize and select wholesale distributed generation and hybrid generation and storage facilities. A recent study from Vibrant Clean Energy indicates that optimizing DER could save California 120 billion dollars compared to a clean energy scenario which does not accelerate distribution grid generation and storage. In addition to supporting demand flexibility, these DER can be useful for resiliency; they also provide land use value, substituting the built environment and brownfields for the disruption of utility scale solar and additional transmission. Recommendation: CEC and CPUC should incorporate wholesale distributed generation and hybrid generation and storage facilities in their energy system modeling. If this is not possible with RESOLVE, California should do parallel analyses with a model such as WIS:dom that can optimize DER. Affordability as a component of equity: Numerous workshop presenters recognized the importance of transportation electrification and building electrification for reducing emissions and stressed that affordable electricity is important for these initiatives. A CPUC White Paper on Utility Costs and Affordability of the Grid of the Future, February 16, 2021 forecast electric rates over the next decade in order to understand the impact of different programs and components of the rate base on affordability, equity, and the climate crisis. Factors identified as likely to increase electricity rates included rapidly rising costs for transmission and distribution infra-structure, as well as anticipated increases for wildfire mitigation. The White Paper is particularly informative because it looks at affordability in the context of TOTAL household energy costs each month, including electricity, methane gas, and gasoline. Analyses which focus solely on California's high (and increasing) electricity rates are deficient because they do not include the substantial potential benefits of electrification for low-income households in decreasing the proportion of income which must go to paying for total energy costs each month, a highly regressive burden. As the White Paper notes, managed transportation and building electrification could save a household with above average energy use in a hot climate zone over one hundred dollars a month in total energy costs. (Figure 38 p 77) That modeling result suggests that priority policy solutions should focus on lowering the barriers to participation in managed transportation and building electrification to allow lower and middle income households and communities to realize these savings.
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Date and Time Comment Was Submitted: 2021-11-19 16:29:58
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