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Renewable Portfolio Standard ("RPS")
R. 18-07-003
July 13, 2021
Reply Comments Recommending CCAs Provide a Lifecycle GHG Accounting in 2021 RPS Plans
The Center for Biological Diversity ("the Center") submits comments on the March 30, 2021 ALJ Ruling identifying the 2021 RPS Procurement Plan filing requirements for all retail sellers. Specifically, the Center is concerned with CCAs and ESPs inclusion of RPS information surrounding procured biomass energy.
The Center urges the Commission to take the following steps with regards to the RPS procurement plans to adhere to the purpose and requirements of the State's zero-carbon energy goals:
- Require that CCAs and ESPs provide a life cycle GHG accounting for all sources of biomass energy that they propose to procure, and justify these procurements in light of California's climate goals and purpose of the RPS;
- Reject proposed procurements from biomass sources that burn biomass fuels along with other fuels such as natural gas, and that emit more than 1100 lbs CO2e/MWh, for failing California's EPS; and
- Enforce Pub. Util. Code Sec. 399.13(a)(8), which requires each electrical corporation to give preference to renewable energy projects that do not cause further harm to communities suffering from high emission levels of toxic air contaminants, criteria air pollutants, and GHG.
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The Center for Biodiversity Reply CommentsALJ Ruling (03/30/2021)
