WOMEN'S
ENERGY MATTERS POLICY PROPOSAL FOR INTEGRATED LONG-TERM PROCUREMENT
was served March 2, 2006 in the Calif. Public Utilities Commission's
Long-term Procurement Proceeding.
(Read
here)
This is an experiment to try
to get policymakers to fix problems with energy efficiency
so it can be used for both "reserves" and "new
resources" - and divert them away from long-term contracts
to support more power plants. The idea is to buy time for
construction of renewables and prevent overbuying of fossil
fuel power (which promotes LNG and creates problems for Community
Choice and renewables).
Our summary recommendations
are:
This “integrated”
proceeding should not race right by the Energy Action Plan's
“higher loading order resources” without first
stopping to consider to what extent energy efficiency, demand
response, renewables (including distributed renewables), cogeneration,
and better combinations of these resources could serve to
fulfill reserve requirements and reduce (in some cases eliminate)
the need for construction of new power plants and transmission.
WEM believes it is premature
to “examine the need for additional policies…which
can ensure construction of and investment in new generation”
without first examining the need for additional policies that
can ensure investment in resources that are higher in the
“loading order.” While current agreed policy places
Energy Efficiency (EE) at the top of the loading order in
the resource selection process, we believe that many routine
current policies mandate against serious use of EE in that
process. Insufficient attention to these resources unnecessarily
increases energy costs, reduces energy security and reliability,
and violates environmental justice.
To weather the “perfect
storm” of climate change, dwindling domestic supplies
of natural gas, and potentially massive economic dislocation
from expensive and uncertain foreign energy supplies, California
should act now to focus investment on energy efficiency and
renewable energy infrastructure.
Therefore WEM offers a Policy
Proposal focusing on the following remedies for barriers to
energy efficiency. Some of these recommendations will also
set the stage for more sensible consideration of cogeneration
and renewables, and other resources if they are truly needed:
Put energy efficiency in the
hands of independent program providers
Develop a Standard Offer EE template
Establish Community Choice energy efficiency opportunities
for cities
Require load serving entities (LSEs) to identify “procurement”
vs. Public Goods Charge EE funds
Bring the Independent System Operator (ISO) and LSE resource
planners to the table for EE planning
Require ISO and LSEs to genuinely consider EE as alternative
resources
Develop data on location of EE resources
Require utilities and other LSEs to provide disaggregated
data on energy use
Target EE by geographical location
Prioritize specific types of EE to reduce the need for supply
resources
Emphasize peak reductions
Determine Avoided Costs by all the non-alternate costs
Link energy savings to payments
If EE is cost-effective, DO IT
Combine energy efficiency with water efficiency and cogeneration;
provide for “over-the-fence” distribution
Utilize Energy Efficiency to buy time to allow investment
in renewables
Our conclusion states:
WEM looks forward to the Commission's taking swift action
on the above proposals, in order to ensure that California
invests first in the cheapest, cleanest resource - energy
efficiency - and prioritizes cogeneration and renewables next.
There is no need for policies to encourage other types of
new generation at this time; indeed that would be counterproductive. |
