This is a welcome step by the commission. The venerable RPS has served the states public interest well expanding the role of renewables on the utility grid, but this proceeding is due. Among other issues we hope are taken up in this proceeding are:
The need for greater specificity in the definition of 'renewable'
I get it, 'renewable' is a really nice word. Makes people feel good about themselves. Unfortunately, as with other words like 'sustainability' it's a little too nice: its vague enough to not to mean much and thus not offend anyone. RPS needs to be specific regarding what renewable means, this could look like a performance standard such as in the Low Carbon Fuel Standard. There are other options.
Differentiate (and monetize) the multiple public benefits of different renewables
In the early years, the IOUs responding to PURPA and the RPS purchased lots of electricity from biomass power plants. Biomass is on-demand, though fairly latent (as opposed to intermittent) and helped meet RPS procurement targets. Just so happens that there are multiple additional benefits to biomass power principal among such as proving alternate means of disposal for agricultural and forestry residues and the biogenic fraction of the solid waste disposal stream (landfill diversion). Since the early years of the RPS the price of wind and solar has come down dramatically, however as biomass conversion is a mature thermal process the price has stayed about the same (if not increased due to permitting costs). As a result, the IOU's have shifted procurement under the RPS to those resources resulting in increased complexity on the grid from intermittency and likely resulting in the increase in the proportion of new base-load/peaking power plants using natural gas to balance supply and demand peaks. Presently we are witnessing a precipitous decline in the states biomass power generation capacity as a result of the pricing terms with utilities. Biomass power generation in California has enabled simultaneous reduction in criteria air pollution from burning of forest residuals and Ag residues and generation of electrical energy for the states electricity ratepayers. Markets for fire hazard reduction thinnings have enabled climate-proofing of a small fraction of the states forestland by creating a market for the low value small trees and slash produced from fire hazard reduction thinning. While wind and solar are important and valuable renewable sources, they do not provide many of the ancillary benefits of bioenergy.
All this is really to say: the state received a whole lot of additional public benefit from directing investment in biomass power plants which it is loosing rapidly as a result of a undifferentiated 'renewables' market place. Weather its the role of the RPS or not to monetize those benefits, I'm not sure, but the state needs to find a way to pay for those additional benefits (ahem… Cap and Trade revenue?), and soon or we are going to loose some very low-cost waste disposal and clean energy infrastructure.
Oh… here's what's on the menu for the new RPS Proceeding
And some additional reading material. May or may not be relevant...
- Morris G. Bioenergy and Greenhouse Gases. 2008.
- Miner RA, Abt RC, Bowyer JL, Buford MA, Malmsheimer RW, O'Laughlin J, et al. Forest Carbon Accounting Considerations in US Bioenergy Policy. J For [Internet]. Society of American Foresters; 2014 [cited 2014 Sep 8];112. Available from: http://www.ingentaconnect.com/content/saf/jof/pre-prints/content-jof14009