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Enron Mail |
John:
I thought it might be helpful to expound on several important principles th= at we have learned through experience regarding RPS/disclosure. I've been= working on these issues for about 2 years, and they have a long and often = complex history. After you've had a chance to digest the below, I'm glad t= o help out in our response. 1. RPS and disclosure requirements need to be developed together. Further,= since environmental disclosure is a requirement in 14 states and RPS in 7 = states, it's important that we don't have overlapping, redundant requiremen= ts on a national level. This can ultimately add to the customer's bill bec= ause of the administrative cost to comply with these requirements. 2. For disclosure, the label calculation (how you derive the fuel mix) is = the most crucial. Suppliers need the following:=20 =09a. the ability to project what they will deliver to customers over a spe= cified "settlement period" (we greatly prefer annually) if they are differe= ntiating their products (either with bilateral contracts or claims about th= e environmental benefits of the product). Otherwise, suppliers would submit= a label with the default mix for spot market purchases. (As Kevin pointed= out below, this allows flexibility in determining how the products will be= sourced -- either through bilaterals, spot and/or renewable energy certifi= cate (REC) purchases). =09b. For suppliers purchasing from the spot market, there needs to be defa= ult fuel mix data provided to suppliers. =09c. After a calendar year, suppliers would provide customers with an annu= al label based on actual fuel purchases ("historic label") for differentia= ted products (including REC purchases and bilaterals). For system mix produ= cts, the projections and historical would be the same. The latter has worke= d well for EES. =09d. There needs to be a lag in-between the timing of label distribution f= or projections and historic label for the product claim. This will allow an= y necessary true up between unanticipated customer usage and the amount of = power purchased for the customer.=20 3. For RPS and disclosure: It is extremely important that any national RPS= /disclosure requirement be developed with a certificate trading program. A= certificate is usually defined as one MWh of renewable energy that has bee= n generated, and represents the attributes or environmental benefits of the= generation separate from the underlying power. This should be a tradable = instrument separate from the power. Renewable energy certificates "RECs" c= an be bought sold, traded separately from power, and allows vital flexibili= ty to get renewables to regions of the country where the supply might be co= nstrained or where renewables such as wind and solar are not conducive to b= eing sited. RECs also provide verification for the purchase of power attri= butes for RPS and disclosure. As Christi was stating below, it is impossibl= e with our sophisticated wholesale markets to track all electrons from gene= ration to end use consumption. The beauty of certificate trading programs = is that they create a secondary market by which the attributes of power can= be tracked through various trades. Certificates trading programs are not a= lways limited to renewable energy. In New England, they are developing a f= ull certificates based system by which all generation would be issued certi= ficates. This helps support the disclosure requirements in the East. Regards, Stacey Bolton Environmental Strategies Enron Corp 713-853-9916 direct=20 713-303-2632 cell=20 sbolton@enron.com <mailto:sbolton@enron.com< =20 -----Original Message----- From: =09Guerrero, Janel =20 Sent:=09Monday, September 17, 2001 7:41 AM To:=09Bolton, Stacey; Mainzer, Elliot; Keeler, Jeff Cc:=09Nicolay, Christi L.; Lindberg, Susan Subject:=09Kevin Presto comments on the summary of Bingaman bill Stacey et al, I thought you should see Presto's comments on the Bingaman energy legislati= on as it relates to environmental disclosure and renewable issues. If you h= ave additional questions, you might want to follow up with Christi Nicolay = or Susan Lindberg. -----Original Message----- From: =09Nicolay, Christi L. =20 Sent:=09Thursday, September 13, 2001 8:45 AM To:=09Shelk, John Cc:=09Yeung, Charles; Rodriquez, Andy; Steffes, James D.; Robertson, Linda;= Shapiro, Richard; Herndon, Rogers; Black, Don; Novosel, Sarah; Shortridge,= Pat; Guerrero, Janel Subject:=09Kevin Presto comments on the summary of Bingaman bill John -- Kevin Presto, head of East Power Trading, had these comments: Under Title IV Electric Reliability Standards -- Kevin says, "NERC should b= e eliminated." Under Title V Subtitle B Environmental Disclosure: -- Kevin says that the "= uniform reporting to consumers, in monthly electric bills, of the known ene= rgy sources" is not good because it supports day-ahead source requirements = for retail suppliers. Enron advocates the ability of customers to choose h= ow to source their portfolio, whether from bilateral contracts done on an a= head basis or purchases in the spot market. =20 John, the renewable portfolio standard provisions later in the draft bill m= ay alleviate this concern, but I don't know enough about how that works. S= everal years ago credits were discussed as credits that accrued to the clea= n energy generator and it can trade those credits. Therefore, the seller o= f clean energy to endusers would need to have a certain amount of clean cre= dits in order to claim it sold clean energy (meaning that the clean generat= or was supported by the marketplace since sellers needed a certain amount o= f credits). That program recognized that you can't specifically source a c= lean generator to a load because electricity doesn't flow that way. Thus, = portfolio sourcing could continue and clean energy is supported. But I don= 't know how this bill's provisions would work. You probably have the Enron= experts on this (used to be Janel G.) Thanks.
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