WEM's POLICY PROPOSAL
WEM'S POLICY PROPOSAL FOR INTEGRATED LONG-TERM PROCUREMENT was served March 2, 2006 in the Cpuc's Long-term Procurement Proceeding
This is an experiment to try to get policymakers to fix problems with energy efficiency so it can be used for both "reserves" & "new resources" - & divert them away from long-term contracts to support more power plants.
The idea is to buy time for construction of renewables & prevent overbuying of fossil fuel power (which promotes LNG & creates problems for Community Choice & renewables)Read entire Proposal -->
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, & better combinations of these resources could serve to fulfill reserve requirements & reduce (in some cases eliminate) the need for construction of new power plants & transmission.
WEM believes it is premature to “examine the need for additional policies…which can ensure construction of & 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 & reliability, & violates environmental justice.
To weather the “perfect storm” of climate change, dwindling domestic supplies of natural gas, & potentially massive economic dislocation from expensive & uncertain foreign energy supplies, California should act now to focus investment on energy efficiency & 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 & renewables, & 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) & LSE resource planners to the table for EE planning
- Require ISO & LSEs to genuinely consider EE as alternative resources
- Develop data on location of EE resources
- Require utilities & other LSEs to provide disaggregated data on energy usee
- 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 & cogeneration; provide for “over-the-fence” distribution
- Utilize Energy Efficiency to buy time to allow investment in renewables
Our conclusion:
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 - & prioritizes cogeneration & renewables next.
There is no need for policies to encourage other types of new generation at this time; indeed that would be counterproductive.Read entire Proposal -->