Vermont Restructuring - AWEA Perspective

[Lisa Marina Brooks <lbrooks@essential.org>]

  Hello energy advocates.  I'd like to offer the perspective of the
  American Wind Energy Association on the Vermont Public Service
  Board's restructuring plan, which was released on Oct. 16.  Our
  view differs in some respects from that of the Conservation Law
  Foundation as provided recently by Lew Milford, and I would like
  to address some of the specific concerns Lew raised.
  
  On RENEWABLES, there are two clarifications: -- 1) in regard to
  the PSB's proposed Renewables Portfolio Standard, Lew states that
  the PSB "suggests that large-scale hydro, specifically
  Hydro-Quebec, could satisfy the standard for existing
  renewables."  2) in regard to emerging renewables, he implied
  that, by making a wires charge for renewables R&D and
  commercialization contingent on other states making similar
  commitments, that the PSB may make no commitment to emerging
  renewables.  Both suggestions are, in our view, inaccurate, and
  deserve a more detailed discussion. 
  
  First, the plan clearly conveys the PSB's intent that its
  renewables portfolio standard (RPS) sustain and increase the
  state's current level of non-large-hydro renewables and that it
  promote emerging renewable technologies.  They "envision a two-
  part portfolio requirement" that would require all sellers to
  meet a standard for existing commercial renewables (specifically
  referencing small hydro, landfill gas, biomass and wind), and a
  separate, smaller standard (a tier) for emerging technologies
  (referencing photovoltaics and fuel cells).  This would protect
  Vermont's current 14% share from existing non-large-hydro
  renewables, including GMP's new 6-MW wind facility, and would
  advance emerging renewables. 
  
  Separate from these provisions, which are definite, the board
  raised the issue of whether large-scale hydro should be included
  in an expanded portfolio in a separate category, though they
  clearly stated the environmental problems associated with
  largehydro.  Therefore, even if large hydro were to be included,
  it would be in a separate tier and thus would not affect the
  other renewables tiers.  From reading the overall plan it appears
  that this idea is simply a concept that was tossed out as one way
  of helping to deal with stranded costs associated with
  Hydro-Quebec. As a separate tier it should not threaten the
  effectiveness of the RPS in promoting the other renewables, and
  knowing Rich Cowart's and the other Board members' strong
  commitment to renewables, I believe that to be the case.  While a
  separate tier for Hydro-Quebec would not be my (or most
  environmentalists') preference, it is really an add-on and could
  well be vulnerable to effective political opposition. 
  
  Regarding the wires charge for renewables R&D and
  commercialization, the PSB did not foreclose that option, but
  implied that one very small state committing research funds would
  not be effective unless combined with funds from other states or
  collected nationally, which they strongly advocated.  Their
  support of an RD&C charge is consistent with their commitment to
  an emerging renewables tier within their RPS. 
  
  On DIRECT ACCESS, Lew wrote that the PSB's plan does not explain
  whether large or small customers would get access first, and that
  this could be a concern if staged access means early choice for
  large customers.  This is a legitimate concern, but the order
  gives no indication that large customers will be going first.  A
  phase-in could be achieved, for example, by geographic areas in
  order to deal with the "institutional, operational, and
  educational prerequisites" that the board refers to in its order.
  In public forums, Cowart has strongly opposed the notion of large
  customers going first.
  
  In closing, I think that this decision deserves the strong
  support of renewables and environmental advocates.  It contains
  far stronger renewables policy than the temporary and
  insufficient price supports offered in the California decision
  and serves as a very strong precedent for other states and
  Congress. 
  
  I have had this discussion directly with Lew, and conveyed to him
  my concern with CLF's consistent opposition to the RPS.  But I
  don't believe that this debate ought to be about RPS vs. wires
  charge.  I think that both have their place.  While we may
  continue to disagree on some details, my hope is that the
  environmental/renewable energy community can come together around
  a comprehensive renewables and efficiency agenda in restructuring
  that will necessarily include a number of policy mechanisms
  designed to accomplish different objectives.  I am well aware
  that an RPS has limitations for some technologies.  It is not the
  most effective way to advance emerging technologies, for example.
  We have consistently supported a wires charge as the best way to
  accomplish some items on the public interest agenda, but simply
  believe that an RPS is a more effective way to advance
  commercially ready renewables in competitive markets. 
  
  This ought not to be seen as a zero-sum game, and if we work
  collaboratively as a community on broad based federal and state
  strategies, we have a far greater chance of winning the most out
  of this challenging opportunity that we are together confronting. 
  
  
  Randy Swisher
  Executive Director
  American Wind Energy Association
  
  
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