Out-of-Tune Requirement
Here are five more reasons why Bingaman’s draft RPS proposal should not make it out of committee.
All Programs Aren’t Created Equal. The proposed national RPS ignores the states’ hard-won experience managing RPS programs and gives Washington bureaucrats little latitude in dealing with state-specific concerns, such as the treatment of out-of-state generation, utility cost recovery mechanisms, and compliance/enforcement. Though the draft says that "DOE shall consult with states having RPS programs and facilitate coordination between federal and state programs to the maximum extent practicable," this arrangement puts the feds in the driver’s seat and provides no assurance that federal legislation would avoid working at cross-purposes with state programs.
All States Aren’t Created Equal. Several states have insufficient renewable resources at their disposal and, under this legislation, they would be forced to comply with the mandate by purchasing renewable energy certificates (RECs). Because the target is set so high, it’s easy to predict that few, if any, RECs will be available for sale. Without active exchange of RECs on an open market, this legislation would punish some regions of the U.S. and reward others.
The Plan Doesn’t Account for T&D. The transmission and distribution (T&D) infrastructure capable of handling such large increases of renewable power doesn’t exist today, and I doubt it will be in place by 2020. Federal control of T&D planning and project approvals, as is now under consideration in Congress, will pit Washington against states and municipalities. I predict local sovereignty will ultimately prevail (see p. 20).
The Feds Won’t Share Control. The Environmental Protection Agency trusts qualified state agencies to manage their air pollution control program with one contingency: State rules must be at least as stringent as the federal rules. Any rational national RPS legislation should give that same flexibility to individual states, but Bingaman’s proposal lacks that element; it relies solely on federal command and control.
Investment Dollars Are Scarce. The majority of U.S. renewables projects are either owned and operated by merchant suppliers or are privately developed and then sold to a utility. Both paths require a developer to take significant financial risk, yet very few investors remain active with our financial markets in turmoil. Who will now assume the developers’ risk?
Write a More Harmonious Song
In its current form, this is an ill-conceived national RPS program that would order all states to march in lock step to Washington’s political beat. Senator, if you compose your next legislative draft with an ear to these concerns, you may have many states singing in concert for a national RPS. If not, you’ll be singing alone.
--Dr. Robert Peltier, PE, Editor-in-Chief
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