SCE Comments on DG and CHP Policy Roadmap Staff Report

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SCE Comments onDG and CHP Policy
RoadmapStaff Report

• Southern California Edison
• May 7, 2007

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Objectives of a Sound CHP Policy

• Reduced Overall Fuel Consumption
• Reduced Overall Emissions
• Non-Participant Electric Ratepayers Held
  Harmless, and Actually Share in the Benefits
• Non-Degradation of Electric System Reliability
• Development of Premium Efficiency Standards to
  Ensure Optimum System Performance

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Current Incentives

• Installation Credits
• Tax Incentives (PTC and ITC)
• Possible Waiver of Stand-By Charges
• Net-Energy Metering
• Possible Waiver of CRS Payments

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Summary of Comments

• Efficiency of CHP Varies Greatly
• SCE Actual Performance Data Shows Only 5 of the
  Projects Meet the Claimed 80 Efficiency Standard
  
• Emissions Inversely Proportional to Efficiency
• Many CHP Projects Actually Increase Emissions
  Compared to CCGT Industrial Boiler Alternatives
• Design and Performance Criteria Are Needed
• Size and Operate CHP Systems to Meet On-site
  Thermal and Electrical Load
• Monitor Performance to Insure Electrical Export,
  is Incidental.
• Comply with Local Air Quality Standards
• With Verifiable Design and Performance Standards,
  New CHP Can Be An Important Part of the States
  Energy Mix

5
Cogeneration Technology Background

• Sequential Use of Energy to Produce Electricity
  and Useful Thermal Energy

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The CHP Industry Highlights 77 to 80 Efficiency

• US Combined Heat and Power Association
• .. CHP systems achieving efficiencies
  exceeding 80 are frequent, and some systems have
  been shown to reach levels in excess of 90
• American Council for an Energy Efficient Economy
• The most efficient CHP systems (exceeding 80
  overall efficiency) are those that satisfy a
  large thermal demand while producing relatively
  less power.
• CAC / EPUC - March 2, 2007 Testimony Uses 80
• CEC Uses 85 for Comparative Examples

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SCEs Cogeneration Portfolio 2003
SCE 2003 reported data only 5 of projects meet
or exceed 80 efficiency