![]() The ARB Scoping Plan for AB 32 requires 6.8 million metric tons (MMT) of reductions from cogeneration the lower efficiency requirement proposed in this bill would make it harder to accomplish this goal. Lowering the minimum efficiency level to 40% for fuel cells runs counter to the goals of the California Air Resources Board (ARB) Scoping Plan under AB 32 for cogeneration.The CPUC would likely only take either of these steps if presented with a compelling showing by fuel cell proponents that there would be significant benefits of these approaches. The second would be to adjust the upfront incentive to fuel cells through the SGIP program in order to compensate manufacturers. ![]() It is already within the CPUC's authority to create a fuel cell tariff under this code section. ![]() The first would be to modify Public Utilities Code SectionĤ54.4 to allow fuel cells' simultaneous production at lower efficiency to qualify for that rate. If the goal is to promote more fuel cell adoption for California, the CPUC believes there are two approaches that might be more appropriate than changing the statutory definition of cogeneration. In addition, the bill's combination of changing the definition of cogeneration and lowering the thermal efficiency requirements would allow lower efficiency fuel cells to access the gas schedule designed for high efficiency cogeneration. This bill would also create administrative and regulatory complexities related to the definition of cogeneration for non-fuel cell applications. However, the CPUC is concerned the bill would have unintended consequences to the state's policy direction related to greenhouse (GHG) emissions reduction goals, the Self-Generation Incentive Program (SGIP), and the qualifying facility (QF) Program. The CPUC recognizes the author's and sponsor's intent to encourage the development of the state's fuel cell market. SUMMARY OF SUPPORTING ARGUMENTS FOR RECOMMENDATION: This bill would modify the definition of "cogeneration" to apply more widely to fuel cell technologies by changing the term "power production" to "generation of electricity." The bill would also reduce the minimum thermal efficiency requirements to be considered cogeneration from 42.5% to 40%, specifically for fuel cells. ![]() LEGISLATIVE SUBCOMMITTEE RECOMMENDATION: OPPOSE UNLESS AMENDED Pamela Loomis, Director Office of Governmental Affairs (OGA) - Sacramento
0 Comments
Leave a Reply. |
AuthorWrite something about yourself. No need to be fancy, just an overview. ArchivesCategories |