Tom Adams
October 30, 1997
Introduction
This document scopes some of the environmental issues that might inform the design of a CMO for Ontario. It is intended that this document will assist TAT Team #3 in deciding what environmental issues it should consider for further examination. The document is intended for circulation to all interested parties and the author invites any comments.
One of the guiding principles used in drafting this document is that the CMO, as a pure intermediary, should not be responsible for the environmental impacts of power production upstream of the CMO or social considerations related to consumer behaviour downstream.of the CMO. Some advocates propose that the CMO be responsible for dispatching on an environmental merit order and propose adders that do not flow through to price directly. Some also suggest that the CMO should be responsible for DSM. Some have suggested that the CMO might play a role in collecting environmental surcharges on imported power. Those approaches are not adopted here.
There are actions the CMO can take to facilitate some types of environmental initiatives. An example that is discussed here is green power marketing. In addition, a discussion is included here about some of grid access rules that might have particular significance for distributed generation.
This note does not address the issues of appropriate environmental regulation mechanisms or the environmental rules that might apply to suppliers to the Ontario market or users of the Ontario transmission system who are located outside of Ontario
Items that might go forward for further examination are identified as bullets.
Green Power Marketing
The basic concept of green power marketing is that individual consumers might someday be able to discriminate between power suppliers and might exercise this choice in favour of renewables, "ABCAN" (i.e., Anything But Coal And Nuclear), or similar products. Some advocates, including Energy Probe, hope that customer choice could promote renewable supplies without making renewables suppliers dependent on government or regulatory intervention for set-asides (which have been proposed by IPPSO in its submission to the Macdonald Committee). Optimistic green power supporters expect that bidding up the price of greener, more efficient sources, might have the effect of depressing the price of "black energy", an effect that would tend to retire or phase out less preferred options more quickly than would otherwise be the case. Green power is now being sold at a premium value in some jurisdictions.
In my view, green power marketing schemes should address the environmental consequences of the electricity required to meet green market requirements, not the particular technology required to generate the power (although there is often a relationship). It is important that the emissions profile of all units, new or otherwise, be reflected in the value of the unit (in part because such valuation will help get less environmentally preferred units shut down faster). One way to ensure this is to encourage existing units with environmental advantages (i.e. existing hydropower) to sell their product into a premium green market. A problem with this approach is that attaching a preference label to existing resources does little in the short run to promote changes in the generation mix.
Measurement, quantification and reporting, all of which the CMO might play a role in, are important for the credibility of green power products. Some kind of an independent auditor (perhaps the CMO or a separate industry-sponsored body) will be required to check up on marketers claims, see that it was any power claimed to be produced actually was, and confirm any claimed amount of emission reductions. In Ontario Hydro’s discussion paper "A Regulatory Framework to Promote Sustainability (29 February 1996), the suggestion is made that generators could be required to submit annual environmental reports which describe the impacts associated with the generation it is selling into the Ontario market. This proposal would help make the auditing function transparent.
A key verification issue is double counting. Green power markets must be able to demonstrate a one-for-one correspondence between "green" power sold and green power produced/procured. The CMO could report periodically on the balancing for green power producers/marketers.
There has been some of public discussions of the alleged "green washing" by green power marketers in New England. A basic problem for green power is to be that usage of the grid allows only an indirect interface between customers and producers. Another basic problem relates to the incrementality of alleged "green power". Attachment 1 and 2 discuss these issues.
The choice of a "poolco" or a "bilateral" market/dispatch mechanism would have implications for green power marketing. In a marginal price pool-based power market, one method of dispatching green power would be to have green power producers under contract with consumers for an environmentally enhanced product to bid a zero price when available (wind power producers and perhaps others will probably want to do this anyway). In order to calculate foregone emissions, all producers would have to report the type of facility they are using and producers serving the green power market might be required to identify themselves. The displaced emissions should be easy to verify by looking at what would have happened without the contracted green power. Consideration might be given to having all the information in the dispatch bidding public. A contract for differences between producers and consumers will probably require terms to specify minimum running requirements for the environmentally preferred units. Some standard balancing calculation–for example annual production or procurement meeting annual sales–might become an accepted standard for such CFDs.
Some environmentalists advocated a bilateral market and dispatch mechanism, the attraction being a perceived enhancement of transparency and assurance of "greenness". Specific minimum running requirements for particular units will be required in a bilateral market. The load balancing methods used in the bilateral market will have to be audited, as it will under the pool approach.
Recommendation
- Team #3 might seek examples of actual or proposed green power contracts from jurisdictions with different market and dispatch mechanisms.
System dispatch, generation reserve, and transmission pricing
Dispatch rules for intermittent generation should be established by the CMO. Day ahead bidding and/or scheduling could present a significant problem for intermittent units, particularly if bid quantities must come in the form of hourly or half-hourly firm deliveries.
If a pool is adopted, the design of the pool needs to allow non-dispatchable/intermittent units (like wind) to bid a zero price. Some advocates like Enron suggest that a price of zero "contains no information". My view is that the volume available at a price of zero is a matter of significant informational content. Unless, a large portion of the power supply comes from such non-dispatchable sources, having some zero bid power may not present a issue requiring resolution.
The method used for managing reserve requirements may have to take special account of intermittent units. The principle that should apply is that generators should be responsible for their own reserve requirements. Should there be a pool, intermittent generators may receive pool payments that reflect any special reserve requirements these units impose on the system. If the market share for intermittent units is small, the reserve impacts will be small, but that should not justify ignoring the problem.
Transmission access and pricing will be a particularly important for distributed generation. Some method of locational pricing of power or at least valuation of regional voltage support should be used by the CMO. Ultimately, the result should be some fair method of crediting local suppliers for any transmission system cost avoidance.
Recommendation
- Team #3 might seek information on how wind power is dispatched and marketed in Alberta.
*******************
Attachment # 1
GREEN SHELL: Clean Power’s Dirty Secret
June 1997
By JON ENTINE
Special to The Progressive Populist
The coming deregulation of the country’s last monopoly, electricity, has some mega- utilities and New Age "green" marketers working hand-in-hand, with both poised to reap a financial windfall. Consumers and the future of green energy may not fare as well.
Many renewable energy advocates contend that this alliance may slow or even end the move toward a viable, long-term clean energy market. The result of the current deregulation strategy, they say, would be to create dozens of energy marketing "shells" with little protection for consumers or assurance that renewable energy will have a significant place in the future energy mix.
This problematic union comes with the quiet blessing of two lobbying groups that normally are at odds: ultra-conservative Republican lobbyists and high-profile environmentalists. It’s an uncomfortable relationship, with each side betting it can ultimately control the process.
Congress and many states are laying the groundwork for the breakup of the electric utility industry. They are using as a model the deregulation of long distance service, which has reduced rates for long distance users, although costs for basic phone service have gone up. Studies indicate that competition could shave as much as 40 percent off the average electric bill, although the greatest savings are expected to go to industrial and large-volume consumers.
At stake is an estimated $220 billion a year spent on electricity generated by private industry. At risk is the future of the fragile renewable energy market which seeks to develop long-term alternatives to dirty fossil fuels and potentially dangerous nuclear energy. The potential spoils from energy deregulation has led to an unusual alliance between energy deregulation supporters and green pricing advocates:
Based on the early returns in New England, green pricing has not faired nearly as well as advocates hoped. In pilot deregulation projects in New Hampshire and Massachusetts, electricity rates have dropped, but almost entirely as a result of below-market pricing by marketers angling to net customers. Rates will kick up considerably with full deregulation. State officials also say that the pilot has resulted in no clean energy being added into the overall energy mix, despite crafty promotions by green marketers who are charging consumers a price premium over other pilot participants.
Green Debits at Working Assets
In 1996, New Hampshire became one of the first states to open a fraction of its market — 3 percent — to competition. The most aggressive social marketer is Working Assets Green Power, a sister company of Working Assets Long Distance. The San Francisco-based company has developed a loyal following generating upwards of $500 million a year in revenue by giving away pints of Ben & Jerry’s ice cream and donating 1% of billings to activist social causes.
"Working Assets offers New Hampshire consumers NUCLEAR FREE ELECTRICITY," screamed a company press release. "No coal or Hydro-Quebec power either." CEO Laura Scher not only pitched clean energy, but low prices. "We are offering people a chance to save money and save the environment at the same time," chortled CEO Scher. Working Assets lured consumers with promises of "solar" and "wind" power, and Scher mused about the day her company could offer 100% renewable energy.
But Working Assets’ promises appear more green wash than green power. It charges its trusting customers the most of the thirty-odd pilot participants, as much as 53 percent more for an energy mix that is overwhelmingly nuclear, coal and oil. Not one electron in New England comes from solar or wind generators.
Working Assets has used similar green marketing tactics in its other businesses. Although CEO Scher is regarded as a star in the socially responsible business movement – she is on the board of Business for Social Responsibility and has been a featured speaker at the Students for Responsible Business annual gathering – her company’s most distinctive characteristic is not its vanilla collection of commodity services but its marketing acumen. Working Assets offers electricity, telephone access, Internet connection, credit cards and paging services through relentless campaigning on "liberal" issues, from gay rights to ‘saving the environment.’ It is best known for its full-page advertisements in liberal publications like Nation, E-Magazine and Utne Reader urging its customers to "save the world" by making lots of long distance calls.
Working Assets is structured like a classic "green shell" thriving on the idealism of its customers and feeding off the scraps created by the loosening of controls in the telecommunications industry. It has no proprietary products, but offers "pass-through" services developed by other companies.
Working Assets offers a consumer-unfriendly multi-tiered rate structure which defies consumer scrutiny. A quick call to familiar overseas destination like the UK can cost as much as 80 cents versus 12 cents for AT&T and MCI. Domestic rates tower over its competitors. While it claims its long-distance rates are "lower" than the "Big Three", they range from 33 percent more on domestic calls to 400 percent or higher than AT&T, MCI and Sprint on international calls. Working Assets rates range from 12 cents to 32 cents per minute using an indecipherable two-tiered, multi-celled plan based on mileage. Its competitors long ago switched to consumer-friendly one or two-rate plans.
Using numbers supplied by WALD, a long distance telephone customer that
it charges $1,450 a year would pay AT&T about one-third less under
AT&T’s One Rate Plus plan and 17% less than AT&T and Sprint’s no-fee
one-rate programs. Working Assets does pledge to contribute one percent
of billings to charity, which would amount to about twenty-five cents on a typical $25-a-month bill. The extra $24.75 would go into Working Assets’ bulging pockets. Smaller competitors like Affinity and EarthTones have lower rates and simple one-rate plans, and kick back a far larger slice of their profits to environmental causes.
Working Assets also offers a credit card with rates set at 18.65 percent far above the national average, and an uncompetitive Internet service. On the other hand, it has appealing ads with smiling lesbians
and pints of Ben & Jerry’s ice cream which it gives away "free" to
customers. We can only assume that Working Assets has learned that there
are plenty of environmentalists and gay activists who are eager to pay a
hefty "green premium" for what amounts to commodity services.
Brown Energy from Green Marketing
Until its dalliance in the green energy market, Working Assets green
marketing strategy could be considered little more than clever
marketing. The stakes in the energy business are far higher, however. To
the extent that it, or any company, was seriously committed to offering
cleaner energy, it could have contracted with hydro or renewable
generators who actually generate "green" electrons. However, Working
Assets did not contract with alternative energy producers, or even
propose a plan to nurture development of green energy.
It turns out that Working Assets buys its energy from New England Power
Company (NEPCO), a subsidiary of the $2.3 billion New England Electric
System (NEES), the region’ s
second largest utility. It’ s also the "dirtiest", according to Rob
Sargent of the Massachusetts Public Interest Group. NEES holds shares in
four nuclear power plants (including Seabrook 1) and has 40 Superfund
toxic waste sites. On the other hand, NEES has pledged to shutdown some
of its oldest coal plants.
As is increasingly familiar in the self-righteous green business
movement, reality is a lot messier than the rhetoric. The energy brew
that heats the designer coffee and toasts the morning bagel in the homes
of Working Assets’ trusting customers is generated almost entirely from
coal, nuclear, oil, natural gas and sources with some and hydropower.
Working Assets got away with its green branding tour de force because
under the deregulation pilot, marketers did not have to disclose energy
sources. And since everyone in the region, draws off the regional energy
pool, the identical electricity mix goes into all homes.
Stung by criticism, CEO Scher released a carefully-worded mea culpa,
saying that, "Time constraints limited our ability to incorporate more
renewable sources and work more closely with environmental groups." More
than a year after rebuffing disclosure requests from renewable energy
advocates, Scher also disclosed that Working Assets had arranged to
purchase shares of the output from 11 of NEPCO’ s power plants,
including hydroelectric,
natural gas, landfill gas, and oil-pumped storage facilities. "None of
these sources are nuclear plants [sic], Hydro-Quebec (which destroy
lands) or coal facilities," Scher now writes.
Working Assets is not the only company pushing the green marketing hot
button. Northeast Utilities, the primary owner of the region’ s nuclear
capacity, recently offered
customers in the Massachusetts pilot 100% hydroelectric power. Both
supply already-generated electricity from current sources, but arranged
for accounting contracts to justify their green market pitches.
Critics have raised two issues with the Working Assets/ Northeast
Utilities marketing claims in New England. Customers were not told that
all energy producers, clean and dirty, send their electrons to a central
grid where they are mixed and sent into homes. So regardless of where
the power is generated, everyone gets the same energy mix. According to
the New England Power Pool, 26 to 60 percent of that energy is nuclear.
Most of the water generated power comes from Hydro-Quebec. Less than 5
percent is non-hydro renewables, primarily
landfill gases and trash-burning incinerators.
The second criticism goes to the issue of whether green marketing will
result in more green energy. MIT economics chairman and NEES board
member Paul Joskow says that green marketers in New England did not
contract for any additional cleaner energy to be fed into the grid, but
merely rearranged existing contracts. "They’ re basically reselling
contracts that have been designated for hydroelectric facilities, for
example, that have no short-run effect whatsoever on the dispatch of
generation in the area, and have no positive effect on the environment."
And none of the marketers engaged the complex issue of what constitutes
green power – and whether nuclear energy is one viable alternative in a
long-term cleaner energy policy. In fact, nuclear energy is renewable
and with advances plant design and in deep core disposal technology,
many environmentalists consider it a better alternative to coal
generation.
In her defense, Working Assets CEO Scher says her intention is to
create a "critical mass" of demand so that "green" companies like
Working Assets will be able to offer "real" green energy in the future.
Debate Over Green Pricing
These revelations have sparked considerable outrage among renewable
energy advocates, who have repeatedly warned about the dangers of a sappy
affair with green marketing. One likely outcome, they say, is that in a market
dominated by major utilities and hot-button green marketers, and without
a comprehensive plan, slack demand could permanently relegate "green"
energy to a niche product.
The free market green pricing strategy represents a fragile tactical
alliance of conservatives and some key environmentalists. EDF and more
recently the Natural Resources Defense Council appear to have climbed on
the free-market bandwagon. Their goals diverge, however. While key
congressmen, such as Bliley, collect huge contributions from deep-pocket
utilities – USA Today estimated that energy industry lobbyists expect to
spend $50 million on this issue alone in 1997 – environmental advocates
are betting that there will be a steady increase in demand for cleaner
energy supplies, even at boutique prices.
That outcome rests on the risky demand-side proposition that residents
will pay more for so-called "clean" energy. Despite surveys that claim
that 60 percent of electricity customers would pay marginally more for
"green" energy, Working Assets was able to sign on less than 100 New
Hampshire homes and 750 customers in Massachusetts. Overall, only 1.2
percent of those eligible to participate in the Massachusetts pilot
chose the green option. The figures are far below predictions, and raise
concerns that the premise on which green pricing is based, backed so
fervently by the mainstream environmental groups, may be fundamentally
flawed.
EDF and NRDC argue that it is too early to give up on the free-market
model. California, which is the big enchilada of energy deregulation, is
building in mechanisms that should result in more clean-generated
electrons being added to the mix. In other states, like Colorado,
Minnesota, and Michigan, some marketers are actually proposing to add
wind-generated energy into the mix; Arizona Public Service has announced
a solar project. But energy advocates warn that without continued
regulations, these projects may relegate alternatives to permanent niche
status as boutique premium-priced products. The mix will only change,
they say, if increased demand for "green power" causes existing
renewable-fuel plants to be utilized more, or new plants to be built,
while nuclear and coal plants are shut down. But producers are not
likely to mothball less expensive "dirty" plants as long as customers
are willing to buy that output.
Undeterred, the Environmental Defense Fund recently jumped into the
green marketing game with two very different projects. In May, it
announced a deal with the Bonneville Power Administration to offer
"environmentally beneficial" energy at premium
prices. But as with the New England offerings, no new alternative energy
is being generated. In contrast, EDF has established a joint effort with
Massachusetts-based ReGen Technologies to add wind and solar electrons
to the New England grid.
In California, where full-competition begins January 1, the Natural
Resources Defense Council gave its blessing to a plan that will forces
consumers to pay for some of the utilities debt from unprofitable
investments in nuclear plants in exchange for the utilities’ backing of
green energy projects.
Citing support for green energy voiced by Bliley and other nuclear
utility industry supporters, renewable energy advocates warn against
deregulation fever. It "attacks the basic role of government to control
the power of monopoly corporations," claims Ed Maschke, executive
director of the Public Interest Group in California. "It is set up by
the political contributions of the large industrials who demanded and
got access to cheaper power
wheeled from other suppliers … and see [deregulation] as a brass ring
in paying off decades of bad economic decisions."
"The sham green power marketing schemes offered in some areas," adds
Bill Magavern of Public Citizen, "are already being used by
anti-environmental leaders as a rationale against enacting federal clean
air and other measures protections" to support the development of
renewables and energy efficiency.
Shake Out in the Environmental Community
The outbreak of misleading claims by social marketers was a major issue
at a recent Attorneys General meeting in Washington, DC., where New
England officials presented the details of their less-than-successful
experiences. Yet the alliance of the huge utilities with mainstream
environmental groups and conservatives in Congress could very well
result in utility deregulation going forward with little monitoring and
few if any disclosure requirements. The promise by deregulation
advocates of lower prices may
also turn out to be a mirage. The below-market teaser rates now
available in Massachusetts and New Hampshire will certainly go by the
wayside once the pilot period ends and companies have to pass along the
"stranded costs" from years of investments in problem-riddled nuclear
energy.
The green market controversy has exploded inside the environmental
community like a bombshell at a family reunion. In an attempt to
preserve its fragile alliance, mainstream environmental groups have
tried to keep the issue out of the press. However, the tight ship of
"silence" has begun springing leaks. Articles have already appeared in
some environmental journals, including an editorial in Energy magazine. But
other liberal magazines usually hot to crusade for environmental reform
have inched away. Although editors at E-Magazine was interested in
running with the story, they reportedly told writers they did not feel
comfortable criticizing "green businesses" with "good intentions," and
were reluctant to step on the toes of such a major advertiser as Working
Assets.
Paul Jefferiss of the Union of Concerned Scientists warns that the
romance with green marketing risks turning the future of renewable
energy over to those least interested in nurturing it. "We believe," he
said, speaking on behalf of the UCS, "that the biggest risk to
renewables development now is reliance on the unproved assumption that
renewable energy will prosper without policy support in competitive markets that
ignore external costs and benefits."
Renewable energy advocates note that similar to recycling, it may take
years before there is enough demand for renewable energy that is price
competitive with fossil fuels. Until that time, caution and deliberate
controls remain necessary. Adds Maschke, "In the end, deregulation is a
sham. At a time when we need focused regulation to increase
conservation, we are leaving this to the market."
The big test for green pricing comes in California. All sides stress
that for green energy to become a viable option, accountability and
disclosure are key. "Building a market on fraudulent advertising,"
remarked MIT economist Joskow, "is not a long-term formula for success."
***********
Jon Entine is a maverick journalist who specializes in business ethics.
He won a National Press Club award in 1995 for "Shattered Image: Is The
Body Shop Too Good to Be True?" published in Business Ethics magazine.
He has also written extensively on the questionable marketing of Amazon
"rainforest" products. His work appears in progressive journals like
Utne Reader, Dollars and Sense, and The Progressive Populist, as well as
mainstream publications including The Chicago Tribune, The Sunday Times
(UK), The Toronto Globe and Mail, and The Guardian (UK).
Entine has also won more than a dozen major awards for his television
reporting with ABC News and NBC News, including two Emmys for
documentaries on reform movements in China and the former Soviet Union.
He lectures on business and journalism ethics, has been a featured
speaker at the Natural Products Expo, and is finishing a book for
Macmillan on why blacks dominate sports based on his award-winning NBC
documentary "Black Athletes: Fact and Fiction." He is also an active
member of Business for Social Responsibility and Co-Op America.
Entine can be reached at (614) 258-9492; Email: runjonrun@earthlink.net
Excerpted from the article of the same name in;
The Progressive Populist, vol. 3, #6, June 1997.
copyright Jon Entine
All rights reserved
*******************************************************************
Appendix 2
(This is the first draft from summer ’97 of "Standards for Canadian Green Power" by Jason Edworthy, President, Nor’wester Energy Systems and Executive Director, Vision Quest Windelectric Inc.. A revised draft is not yet complete.)
Hello Group.
As discussed, here is a first cut at Standards for Canadian Green Power. It focusses on Electricity, and proposes six major criteria, with a variety of sub-criteria.
Please review and comment on these to the group. I hope this stimulates constructive discussion. I hope to have these reviewed over the next two weeks, then issue Round 2 versions.
Worries: I worry about these becoming too complex and/or too beaucratic. Let’s try to keep them as simple as possible. I also worry about clarity, especially to those outside of the group – we must be clear enough that there are no misunderstandings. I also worry about tangential discussions – if a discussion or thread starts which needs to be discussed, I would encourage that to be a separate thread, that when resolved is brought back to this one.
Thanks everyone – I look forward to your responses!!
Jason Edworthy
PS. The work follows as text below. If you want a Rich Text Format version as an attachment, please email me privately and I will be pleased to send it to you.
——————————————-
Green Energy/Emissions-Free Energy Standards – DRAFT
1.Electricity
Electricity is the main form of Green Energy currently under consideration. It is, however, likely that other forms will develop (see further discussion below)
1.1 Technology
The technology from which the electricity is derived or generated is the main criteria, but is closely related to others below since each technology has its own merits and pitfalls. There is confusion in the minds of the consumer about such concerns as: Which is greener, product X or Y? What is the difference between Green, Greener, Greenest? Is a blend or mix of technologies valid, or is it Greenwashing? In these draft criteria, the technologies are divided into Emissions-Free (the no brainers ) and Emitters (the ones that have smokestacks anyway). This division is purposely based on the optics, and at the burner tip , rather than the more contentious full fuel cycle determinations.
1.1.1 Non-Emitters
1.1.1.1 Solar PV. Photovoltaics operate without emissions of any kind. This does not include hybrids, and most likely will include the new grid-connected mini inverter systems.
1.1.1.2 Solar Thermal. These are the somewhat rare Luz type systems, where mirrors are used to heat fluids for fairly conventional steam turbines.
1.1.1.3 Wind. Windfarms or individual wind turbines.
1.1.1.4 Small Hydro. Run-of-the-river type (no flooding or dams purpose built, may take advantage of existing civil works). Other definitions suggest this must be under 15 (or 20?) MW, but this should be discussed (why limit it, if you have the other parts of the criteria?).
1.1.1.5 Other: fuel cells? other?
1.1.2 Emitters
1.1.2.1 Bio-mass (wood or wood related burning). Various versions of these technologies, without sustainable forestry practices are just about the same as coal for emissions.
1.1.2.2 Municipal Waste. Includes all sorts of materials from garbage to tires, even restaurant grease. Not much known about what sort of emissions, but must be specific to fuel type.
1.1.2.3 Sewage/Landfill Gas. Burns methane which leaks to atmosphere and converts it to carbon dioxide and other products.
1.2 Track-ability
Measurement, quantification and reporting are important for the credibility of these products. To say a product is cleaner or emissions-free without hard numbers and backup is in reality fraudulent. These products must be real, credible, instill trust, provide value, and ensure consumer protection.
1.2.1 Measurable. Must be able to accurately measure the energy, as in a certified metering system.
1.2.2 Demonstrable Emissions Improvement. Must be able to demonstrate that there is an offset, mitigation, reduction or avoidance of emissions with these technologies. Preferably a permanent one, not just storage or temporary sequestration.
1.2.3 Measurable Emissions Improvement. Not only must we demonstrate it, but it must be quantifiable by some means.
1.2.4 Verifiable. An auditor should be able to check up on the product, see that it was produced, it did result in reduced emissions somewhere, and the amount of reduction can be justified. This should also catch and prevent double counting .
1.2.5 Reportable. If the above criteria can be met, then the product should be reportable to compliance or voluntary authorities.
1.3 Incrementality
This means that a facility which uses the technology is new. Only new uses of these technologies can reduce emissions – we cannot claim benefits from existing ones. This is because existing facilities are already reducing emissions – the goal of setting standards includes increasing industry activity, reducing emissions more, and growing all related activities in order to have a sustained improvement. [this new argument needs strengthening – please help out]
1.3.1 New Facilities. This means new equipment, resulting in new generation. But, this is not easy to define:
is it new capital? is there a threshold or minimum?
is it a new interconnection or metering?
is it something that needs a new permit?
is it the addition of any new equipment which results in a measureable increase in output?
[Discussion. Is a new wind turbine New? Sure. Is an existing turbine with an upgraded generator or new set of blades, which provides a 5% boost to energy over a year, new? Well, maybe the new 5% is, but you must be able to demonstrate the incremental improvement. What if this is a variable speed technology wind turbine, like the Kenetech 33 MVS? That machine could actually be dialed up or down. It has less life when Up, but produced more. No capital cost, but this could be masked by some maintenance work that was needed anyway. One opinion is that only clearly new, separate facilities should be called incremental/new. Another is that clearly demonstrable, needed and measureable improvements which result in increased output will result in the new increment only being new.]
1.4 Sustainability
If one of the goals of this is to improve the sustainability of our energy sources, then an electricity source with a short lifetime should not rate as high as one which is endless . And, this may apply to the technology, or the fuel source.
1.4.1 Technology Life. A longer predicted or known life is better than a short one. In the example above, dialing up the wind turbines will shorten the life of the technology, and should be taken into consideration.
1.4.2 Fuel Supply and Risk. A comparison which includes solar PV, wind and biomass might result in rating the first two as having good long term fuel supply and low fuel risk, but the third one might be rated as having a five year fuel contract, and therefore higher risks.
1.4.3 Sustainable Management Practices. For some technologies, this goes beyond the technology itself and into the source of fuel or the disposal of wastes associated with the process. For example, a biomass plant which uses wood harvested purposely for it, must have a working sustainable forestry plan in place and practising to replace the wood which is burnt, on a schedule which matches or exceeds consumption.
1.5 Emissions Impact
This criteria addresses the relative improvement (or not) on the emissions being addressed. It ranks emissions-free technologies vs other technologies, in a quantitative manner. Think of this as the nutrition label on the green energy package.
1.5.1 Emissions at point of generation ( burner tip ). A list of all emissions which are measurable, whether regulated or not.
1.5.2 Emissions in full fuel cycle . Emissions related to manufacturing, assembly, transportation, construction, decommissioning and reclamation.
1.6 Social Impact
Is there a role for this criterium in green energy ? If so, would this include displaced peoples , or even extend to the practices of firms which generate energy?
Other forms of green energy. So as not to limit ourselves in the future, we may wish to consider, but shelve these other possible forms. Please concentrate on Electricity for now.
2.0 Transportation
3.0 Heat Energy
————————–
—————– End Forwarded Message —————–
Jason Edworthy
1. President, Nor’wester Energy Systems
http://www.greenenergy.com/NESL_web/NESL.index.html
2. Executive Director, Vision Quest Windelectric Inc.
Suite #100, 3553 – 31 Street SW
Calgary, Alberta, Canada T2L 2K7
Tel 403-289-4399 (Nor’wester) or 403-289-4553 (Vision Quest)
Fax 403-282-1238
eMail: edworthy@greenenergy.com
Energy Probe 