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Home My WebLink About12-03-2013 ac weisz ss1Goodwi Heather From: Sent: To: Subject: Attachments: Anthony J. Mejia I City Clerk ùrt.t Òl s¡n lu¡s orìrsÏ)o <¡eo Palnr 5trce1. San Luis öbispo, CÂ g34o: tell8o57t3l..7rcs- Mejia, Anthony Monday, December 09, 201-3 8:16 AM Goodwin, Heather FW: Marin Clean Energy response to Mr. Phelps Response to Mr.Phelps Dec 5 2013.pdf RE CËIVl.:n DEC 0 g 20t3 sL0 cT"['Y i: , From: Dawn Weisz Imailto:dweisz@marinenergy.com] Sent: Thursday, December 05, 2013 2:05 PM To: Jim Phelps Subject: Marin Clean Energy response to Mr. Phelps Mr. Phelps, Your December 2nd letter sent to our agency and other parties regarding greenhouse gas accounting is unfounded and intentionally deceptive, Crafting serious accusations from incomplete and misleading information ís irresponsible and a disservice to our community. ln response, and as a backdrop to this discussion, it is important to note that the market for energy and environmental products is largely financial - not physical - which essentially means that such products are typically bought/sold across geographic areas and timelines that may not "match up" exactly with customer usage patterns and/or locations. This is an industry standard practice used by all utilities operating in California (including PG&E), that provides the necessary operating flexibility to effectively operate a utility system and serve customers on a cost effective basis. To toss accusations at our agency for following standard industry protocol is irresponsible and disingenuous. ln the simplest of terms, MCE made a commitment to deliver a lower emission factor than PG&E, and that commitment was honored, This commitment was made quite a while ago (in advance of 2011) and has not changed. Revisionist history, by contrast, implies that MCE altered its commitment as a marketing ploy, or gimmick, to gain some after-the- fact advantage... whatever that may be. This did not occur as the commitment was clear and did not change over time. It is accurate that procurement activities were trued-up after the 2011 calendar year had passed, a practice that is common for certain voluntary programs, including the Center for Resource Solutions' Green-e Energy program. Truing up is necessary for utilities because 1) volumes for customer usage tracked through the California lndependent System Operator (CAISO) is not final until many months after the date of use, and 2) large utilities require time to reconcile variations in energy deliveries within a calendar year with usage and to then create accurate reporting. Due to timing issues affecting informational availability (specifically, timelines affecting the availability of PG&E's "verified" portfolio emissions factor), this true-up was necessary for MCE to honor the commitment it made to its customers. You omitted from your letter, however, that the significant majority of MCE's carbon-free energy procurementfor 2011., which included a large proportion of renewable energy, was completed during the 2010 and 201.1 calendar years. Contrary to your allegations, MCE didn't wait until 2013 to purchase all of its carbon free supply in an attempt to 1 retroactively address this item, it simply performed a true up, as required by industry timing, when the final target was available. You also have failed to note that the referenced carbon free purchases for 201.1. were voluntary (and therefore not subject to any part¡cular timing restrictions), and these carbon free certificates were actually produced during the 2011 calendar year (in November 201-1; the same year in which MCE accounted for the environmental benefits). This approach ensured that the environmental benefits were accounted for during the same calendar year in which the emission impact was calculated. Another deceitful representation you have included in your letter relates to your characterization of Renewable Energy Credits (RECs). ln your letter you include a list of 'problems' and 'problem #4' starts with a comment that, "RECs are not clean power." However, on September L5, 20LL you presented clear comments to the Ross City Council to the contrary, encouraging the councilmembers not to participate in the MCE program¿ and encouraging them to instead purchase RECs. As recorded in the minutes from that meeting (which are publicly available)your comments were as follows: "f they [the councilmembers] o// ogree thot the environment is the rssue, Ross con purchase a Renewoble Energy Certificote (REC). REC's ollow everyone to be green for a fraction of the cost." Thus, in your letter you are not only stating an opinion as if it were fact, but you are attempting to manipulate your audience by assertions that even you apparently do not believe, Finally, we refute your characterization of compensation for our staff and consulting team as it is also inaccurate and misleading. All information about compensation for MCE staff and service providers is publicly available and reviewed by our Board of Directors. ln closing, we note that to the extent PG&E is interested in ratcheting up/true-ing up its procurement efforts to increase clean/renewable energy procurement voluntarily, MCE would welcome this practice. Unfortunately, the only PG&E true-up process of which MCE is aware entails selling off its "excess" renewables so that they don't exceed the 20% CA Renewable Portfolio Standard (by much, if at all). By contrast, MCE has voluntarilv exceeded the CA Renewable Portfolio Standard (RPS) every year since our launch, and also voluntarilv increased the quantitv of RPS enerRv purchases every year' We encourage you to use more accurate and complete information going forward. Regards, Dawn Weisz Executive Officer Marin Clean Energy 781 Lincoln Ave., Suite 320 San Rafael, CA 94901 4t5-464-6020 dweisz@mceCleanEnergv,com www.mceClean Enerqv.com MCE is committed to protecting customer privacy. Learn more at: www.mceCleanEnerq!/.com/privacv 2 h,1¡l RI N llN IìltGY Dawn Weisz Ëxeculive Officer Damon Connolly Chair City of San Rafael Kathrin Sears Vice Chair County of l\4arin Bob McCaskill City of Belvedere Sloan G Bailey l'own of Corte Madera Larry Bragman Town of Fairfax Len Rifkind City of Larkspur Ken Wachtel City of Mill Valley Denise Athas Citv oi Novato Tom Butt City of Richmond Carla Small Town of Ross Ford Greene l-own of San Anselnro Ray Withy City of Sausallto Emmett O'Donnell Town of '[iburon 78-l Lincoln Avenue Suite 32{) San Rafael, CA S4S01 1 (888) S32-3674 nrarin althorilv conr December 5,2013 Mr. Phelps, Your December Znd letter sent to our agÈncy and other parties regarding greenhouse gas ac:counting is unfounded and intentionally deceptive, Crafìing serious acousations fi'om incomplete ancl misleading infcrtmation is irresponsible and a disscrvíce to our community, In response, and as a backdrop to this discussion, it is irnportant to note that the markct fbr energy and envirorunental products is largely financial - not physicul - which essentially meôns that such products are typically boughlsold asross geographic areas and tirnelines that rnay not "matÇh up" exactly with customer usage pâtterns and/or locations. This is an ìndustry standard practice used by all utilitícs operating in Calitbmia (including PG&E), that provides tlìe necessary operating flexibility to effectively operate a utility systcn and serve customers on a cost etl'ective basis, To toss &ccusations at ùur agency for following standard inclustry protocol is iresponsilrle and disingenuous. In the sirnplest of terms, MCE made a commitment to deliver a lower ernission factor flian PG&E, and that commitment was honore<L This commitrnent was rnade quite a while ago (in advance of 2011) and has not changeci. Revisionist liistory, by contrast, irnplies that MCE altered its commitment as a marketing ploy, or girnmick, to gain some after-the-fact aclvantage... whatever that may be. This clicl not occur as the çornmitrnent was clear and did not change over time. It is ascurate that plocurement activities were t¡ued-up after the 201 I calendar year had passed, a practice that is common for ceúain voluntary programs, includìng the Center fbr Resource Solutions' Creen-e Energy program. Truing up is necessary for utilities because l) volurnes ftlr customer usage tracked through the California Independent System Operator (CAISO) is not final until mary months after the date of use, and 2) large utilities require time fo reconcile variations in crnergy deliveries within a calçndar year with us¿ge and to then create accurate reporling. Due to timing issues affecting infon¡ational availability (specifically, timçlines affecting the availability of PG&E's "verified" porfftrlio emissions factor), this true-up was neqessary for MCE to honor the courmihnent it made to its customers. You omittecl from your letter, however, that the significant majority of MCE's carbon-free energy procurement for 201 1, whìch included a large proponìon of renewable energy, was completed during the 2010 and 201 I calendar years, Conttary to your allegations, MCE didn't wait until 2013 to Page 2 purchase all of its carbon free supply in an attempt to retroactively address this itern, it simply perfonled a true up, as required by industry tirning, wherr the final target was avaílable. You also have failed to note that the referenced carbon liee purchases for 201I were voluntary (and therefoÍe not subject to any particular timing restrictions), ancl these carbon free certificates were actually ploduced during the 2011 calendar year (in Novcmber 201 I ; the sarnc year in which MCE accounted for the envirorunental benefits). This approach çnsured that the environmental benefits \ryeÍe accounted for during the same calendar year in which the emission impact was calculated. Another deceitful representation you have included in your letter relates to your characterization of lenewable energy credits (RECs). In your letter you include a list of 'problems' and 'problem #4' starts with a comment that, "RECs are not clean power." However, on September 15, 2011 you presented clear comments to the Ross City Council to the contrary, encouraging the councilmembers not to participate in the MCE program, and encouraging them to instead purchase RECs, As recordsd in the minutes florn that meeting (which are publicly available) your cornments wete as follows: "IJ'they fthe councihnernbers] all agree that the environment is Íhe issue, Ross can purchase a Renewable Energy Certifi.ca.te (REC). R.6C ir allotv everyone to be green Jbr a,fraction of the cost, " Thus, in your letter you are not only stating an opinion as if it were fact, but you are atteurpting to manipulate your audience by assertions that even you apparently do not believe. Finally, we reftite your charactsrization of compensation for our staff and consuhing team as it is also inaccurate and misleading, All infbnnation about cornpensation for MCE staff and service providers is publicly available and reviewed by our Board of Directors, In olosing, we note that to the extent PG&E is interested in ratcheting up/true-ing up its procurement efforts to increase clean/renewable energy procurement voluntarily, MCE would welcome this practicc, Unforfunately, the only PG&E true-up prooess of which MCE is aware entails selling clff its "excess" renewabtes so that they don't exceed the 20% CA Renewable Portfolio Standard (by muoh, if at all). By contrast, MCE has voluntarily exce_edÆd thc CA Renewable Portfolio Standard (RPS) every year since our ìaunch, and also every yeaf. We encclurage you to use more accurate and complete infomration going forward Regards, (-.*\ ()¿9---c--a à Dawn'Weisz Executive Director Marin EnergyAuthority | 781 Lincoln Avenué, Suite 320 lSan Rafaei, CA 94901 I 1 (BBB)632-3674 Inrarin authority conr