GHG Accounting in the Power Source Disclosure Program: 2019 Comments

Summary

Near Zero submitted a comment letter to the California Energy Commission on its AB 1110 Implementation Rulemaking for the Power Source Disclosure Program.

We appreciate the effort the Commission has put into updating the PSD Program to account for the greenhouse gas (GHG) emissions associated with electricity that serves California customers’ loads. We believe the proposed regulations reflect important progress in improving the quality and accuracy of the PSD Program and commend the Commission for its efforts. We provide a set of comments that offer some specific constructive suggestions to further strengthen the Commission’s proposal as well as to identify a set of issues we suggest the Commission may wish to monitor for consideration in future rulemakings.

Our comments focused on the following issues:

1. The proposed PSD regulations would strengthen the quality of GHG emissions accounting for electricity that serves California customers’ loads, particularly in the treatment of firmed-and-shaped and unbundled REC contracts.

2. The Commission should explicitly extend its GHG accounting principles for specified purchases to purchases from large hydropower generators.

3. The Commission should monitor any new research addressing the default unspecified GHG emissions factor that applies to unspecified power because this factor was calculated from 10-year-old market conditions and may be inaccurate.

4. The proposed methods for calculating the GHG emissions profile of load-serving entities that procure more electricity than they have retail sales create potential perverse incentives and potential accounting inaccuracies.

5. The Commission should clarify how it will limit grandfathering of eligible firmed-and-shaped products under contracts executed prior to January 1, 2019.

6. The Commission should monitor the role of electricity exports and consider how a changing net import-export balance may affect the goals and implementation of its PSD Program in the future.

Download the full comment letter (pdf).