Comment Details
| Comment Author: | Bob Yuhnke |
| Organization: | Southwest Energy Efficiency Project |
| Comment Date: | Friday, 19 February 2010 |
| Comments: |
Comment on Accounting Mechanism for VRE Set Aside Program Recommendation: SWEEP is submitting this comment as a supplement to the central points made in the comments from WeCAN regarding the need to ensure that sufficient allowances are allocated to VRE producers to avoid the possibility that such voluntary purchases will not fully displace carbon-generated electricity. The additional point we ask that you consider is the potential effect on the sale of electric vehicles if the public learns that their investment is not actually displacing carbon-generated energy. Electric vehicles and Plug-in hybrid EVs due on the market within the next 12 months can be expected to expand the demand for electricity as a surrogate for fossil fuel use in the transportation sector. The climate benefits of these vehicle technologies are significantly enhanced if the power they use is generated from renewable sources. The purchasers of these vehicles will largely be motivated by climate considerations. As DOE's economic analysis of the cap and trade legislation makes clear, the price of motor vehicle fuels is not expected to be raised more than $0.67 between now and 2030. Higher gasoline prices cannot be expected to drive these vehicle purchases. The incremental purchase price of these vehicles is not justified on purely economic grounds even when the lower costs of electricity compared to gasoline are accounted for. Purchasers will be angry if they invest in a low carbon electric vehicle to be powered from what they believe to be a renewable power source for which they pay a premium price only to discover that they are not actually displacing carbon-generated power. It will be a serious public relations disaster for the WCI to design an emission credits program that does not ensure that voluntary purchases of renewable energy will displace carbon-generated energy. |
| Comments: |
Comment on Emission Attribution for VRE Purchases Recommendation: See SWEEP's comment on Set Aside Program recommendation. |
