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Enron Mail |
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=20 Enron would like to compliment staff on their recommendations for the discl= osure label calculations and offer one suggestion that would accommodate th= e purchase of clean, renewable resources. As noted in our prior comment, w= e would like to reiterate the need for a methodology that recognized attrib= ute contracts. It is a growing practice to contract for the renewable or c= lean attributes of energy that have been generated onto the grid without pu= rchasing the actual commodity power. These attributes are typically referr= ed to as certificates, "green tags" or "renewable energy credits". All of = these terms refer to the environmental benefits of clean power that have be= en generated onto the grid and may be traded, bought and sold separately fr= om the underlying power commodity. The ability to separate the attributes = from the underlying power facilitates the ability for suppliers to offer cl= ean renewable power in regions where it might not be conducive to site thes= e resources. The supplier can then pair the attributes with system power = at the point of sale to Michigan customers. =20 This methodology greatly decreases the administrative reporting burden for = suppliers and also provides a cost-effective form of verification for Commi= ssion staff. Our specific recommendations for accounting for certificates = are as follows.=20 1. Allow suppliers to account for attribute purchases on their fuel labels = by providing proper substantiation that the supplier owns the attributes. = Substantiation can be in the form of verification from an independent syste= m operator of an attribute registry (e.g. Automated Power Exchange operatin= g in California and the Midwest and recently awarded the contract for NePoo= l to build their certificate based system; ERCOT) that the supplier has pur= chased the certificate and retired it on the behalf of the customer; a bila= teral contract showing that the attributes are owned by the supplier, or an= y other method deemed appropriate by the Commission. 2. Suppliers can use the generation data from certificates that have been g= enerated by independent certificate system administrators or generators to = calculate the fuel type and emissions. The certificate purchases would be= weighed with other bilateral contracts and spot market purchases for purpo= ses of calculating the label. 3. In the event that the emissions data are not provided by the generator,= suppliers will be able to use the most recent E-grid data to calculate the= emissions. =20 There are several examples from other State Commissions for accounting for = certificates purchases. The following link shows the methodology that the = Texas Public Utility Staff wrote for calculating labels with certificate pu= rchases. <http://www.puc.state.tx.us/rules/rulemake/22816/22816.cfm<; =20 This modification to the label calculation will allow suppliers who are pur= chasing affordable clean to be delivered to the grid on behalf of their cus= tomers through certificate contracts to depict this on their fuel content l= abel. We appreciate your review of our comments. =20 Stacey Bolton Environmental Strategies Enron Corp 713-853-9916 direct=20 713-303-2632 cell=20 sbolton@enron.com <mailto:sbolton@enron.com< =20
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