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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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