Clean Energy Springfield

Justakim at Ecocene points to an interesting story from National Geographic, about an Australian species of tree, the Wollemi Pine, once thought to be extinct, but found in a remote location in 1994. National Geographic is selling cuttings of the few trees that exist as a way to spread the gene pool around. Justakim frames it as a property rights success (and it is, don't get me wrong).

But I also think it's an example of a more a general meshing of natural and social worlds (the latter being a subset of the former). Often, we look at these worlds as in conflict--Nature's Metropolis, for example, is a book about the intertwined development of Chicago and it's hinterland, the plains region, and how a variety of transportation technologies and market innovations remade the American West, and one thing that comes through quite clearly is the differences in how money works and how nature works. (Think of the difference in day-night cycles in all sorts of living creatures, versus shift work that's needed to get the maximum amount of productivity out of your machinery (where "you" = "General Motors").)

One of the major problems of climate change is how species will cope. In past climate changes, which have been slower, species are often able to migrate together. The speed of "our" change is casting many species' ability to do so this time into doubt. And that's exacerbated by human settlement patterns (sprawl and agricultural) that cleaves natural habitats into isolated patches, with no routes to more habitable climes.

National Geographic, then, is one way to overcome that kind of patchiness: by creating paths through human institutions. Something worth exploring, and keeping an eye on.

There are a few articles of note in today's SJR. Gas prices are always good for an active and amusing comment board, and the buffalo gnat story has, for me anyway, the ring of what's to come from global warming (even if it's not the case that our own infestation is due to warming, some googling suggests that other places are experiencing heavier swarms due to warmer winters).

But, no, my choice for story of the day is the education rally. A common complaint in liberal blogs is with the factionated aspect of the Democratic Party's interest groups. Environmentalists, labor, pro-choice--everybody pulls in different directions at once.

Education, though, ought to be the exception. From the perspective of environmentalism, one of the problems with school funding is that it drives sprawl. Because property taxes are the primary base of local school funding, and municipalities can zone out poor families, one of the drivers of sprawl are middle class households that, essentially, have to buy their way into a good school district.

So if school funding is evened out, and in turn, school quality levels even out, there's less pressure on families to move to sprawling areas, since those areas will no longer have a monopoly on the good schools. This is, of course, an ancillary benefit to the main one of simply doing better by low and moderate income families.

I can't complain too much about the SJR's "In My View" columns, since they were kind enough to run mine. But today's is a doozy. I don't want to grapple with it to much, for fear of granting it legitimacy it doesn't deserve. So let me say this: Mr. Watt's contention is that his back-of-the-envelope probabilistic calculations suggest that there is slim chance that climate scientists can accurately predict the exact temperature the Earth will reach under a business-as-usual scenario. Well, okay. But they don't try to do that. They provide ranges, which are based (in part) on understanding the sensitivity of their models to changes in initial conditions, which Mr. Watt appears to not realize is something that they do. Of course, you must always make allowances for limited space in these columns, but I don't see how his example doesn't fall apart completely when you understand that climate projections are done this way.

CES does a lot on those little individual actions that you, Dear Reader, can take to lessen your carbon burden. And when the clean energy plan was in city council, we tried to get the word out to supporters to contact their aldermen. Other than that, though, we haven't focused too much on policies that can help this carbon shift along.

Well, here's something you can do to help us change that. In March, the Illinois Senate passed the Cool Cities Act, which provides technical assistance for cities that choose to join the U.S. Mayor's Climate Protection Agreement (and, hey, check out the flashy new site!), which is a commitment by the city to reduce greenhouse gas emissions to 7% below their 1990 levels by 2012. Several Illinois cities have already joined (see the map at the bottom of this page).

This is important legislation, because it's a useful carrot for getting cities to join. One of the hurdles to making the commitment is knowing exactly what your greenhouse gas emissions are, for example. And what this bill provides assistance for is taking a GHG inventory, and then figuring out how to reach the cuts they need to make.

So, like I said above, this thing passed the Senate in March. It's now in the House Environmental Health committee (whose next hearing is Tuesday). I have no idea how this process works, but I figure now's a good time to start contacting Representatives. So go find out who your rep is or how to contact them (here), and let them know you support the SB1242, the Illinois Cool Cities Act.

A couple of weeks ago, I posted a snide little thing about warming skeptics who are appalled by the very idea of a climate model. Somehow, I guess through a trackback at RealClimate, Ian Rae found his way here, and took issue with some of my characterizations. A not-bad discussion ensued, at the end of which ... whoops! I just realized that I misunderstood something Ian said (I took his crack about the IPCC as a funding-driven cabal as more earnest than it now appears on a re-read -- Sorry, Ian!).

Anyway, Stentor Danielson at debitage had a nice post a few days later on scientific consensus that I wanted to link to. It's not as topical as I'd planned on it being due to that misunderstanding, but it's an interesting read nonetheless.

Via Richard Layman, the University of Minnesota has a broadscale study of accessibility in the Twin Cities region. For those not up on the latest transportation lingo, accessibility is contrasted with mobility as a way of judging the efficiency of a transportation system.

Mobility looks at the cost of travel on a per mile basis (that is, the speed of travel, basically, but you can also include fuel and environmental costs). Most traffic engineering today is within a mobility framework--traffic engineers want to see cars moving smoothly along, congestion-free.

Accessibility, on the other hand, looks at the cost of travel on a per-destination basis. That is, what's the total cost of a trip to your shopping center or job.

The difference between the two can be seen in that a pedestrian-friendly neighborhood can have low mobility--you move around slowly--but is highly accessible, because you can get to a lot of places, even at that low rate of speed. Personally, mobility seems to me to be an easier standard to measure against, but one that misses out on how transportation is experienced. Mobility also encourages sprawl, since you're only paying attention to the speed, it's easier for overall trip distances to grow unchecked.

The U. Minnesota group has put out a short report on their study so far, called "Asking the Right Questions" [PDF]. It's a reasonable introduction to the idea of accessibility, if you don't have much time.

ALSO: The ability, or desire, of Americans to respond to changes in the price of gas has lessened in recent years. I'm inclined to say that this is the result of people choosing less and less accessible locations to live in (and, of course, our regulated land-use market providing fewer and fewer accessible residences), but it could be something else going on.

Some news on the jobs and clean energy front: a new report on the things we can do to create the green collar jobs that we need to restore our environment and our communities. Grist has a brief overview. This is going to require some attention.

I can be magnanimous--really. So I don't begrudge the coal industry this nifty little story: a 15 square mile section of prehistoric rainforest has been found fossilized in a Illinois coal mine.

The US Senate has been holding hearings about increasing fuel efficiency standards for cars. As they always do, US auto manufacturers had a representative claiming the requirements would cost American jobs. I've been searching for an explanation of that argument with no success. It sounds more like a scare-tactic than an argument.

A series of other articles paint a different picture. First, the list of the most fuel efficient cars on the market is dominated by foreign car companies, with the Toyota Prius topping the list. Then Toyota outsold GM for the first time, while GM lays off workers, had declining profits and falling stock value. It doesn't take a genius to see the pattern here, does it?

This post has been in my head for a while but it was a comment Barack Obama made in Detroit that made me finally type it out.

"Here in Detroit, three giants of American industry are hemorrhaging jobs and profits as foreign competitors answer the rising global demand for fuel-efficient cars," he said.

"The need to drastically change our energy policy is no longer a debatable proposition. It is not a question of whether, but how; not a question of if, but when. For the sake of our security, our economy, our jobs and our planet, the age of oil must end in our time."

Lack of action on the federal level is prompting states to take their own action. Maryland is the latest state to pass their own clean cars legislation. Momentum is building to do the same in Illinois, which is something I'll write more about another day.

Carbon offsets are a tricky problem. I happen to think they are more useful than not, but that's with the presumption that people move their energy use in fits and starts, and offsets are just for the in-bewteen time. Nonetheless, it's always important to keep front-and-center the idea that the energy savings and direct switchover to renewables need to come as they can.

In that vein, Charles Komanoff was quoted in the linked article as saying "There isn’t a single American household above the poverty line that couldn’t cut their CO2 at least 25 percent in six months through a straightforward series of fairly simple and terrifically cost-effective measures." Kindly, Komanoff has followed up at Grist with his back-of-the-envelope calculations backing up his off-the-cuff estimate.

So, if you're interested in fighting global warming, and you're looking at carbon offsets (or even planning on buying into CWLP's green power program when it's offered), go take a look.

I'll be honest, I don't have any sense how big a problem this is in Springfield, but I figure we're mostly an office-culture kind of place, so I thought I'd toss it out. InfoWorld has a piece on how bad corporate habits (and I imagine you can read "bad state government habits" here as well) eat up money through poor IT planning, adding extra computing capacity when the corporation may only be using 15% of their current capacity anyway. And, of course, "eating up money" means "unnecessary carbon pollution." If you do this kind of stuff, go read it.

For everybody else, though, there's this concluding paragraph:

One of the real take-aways for me reading this report, though, is a lot of companies are in need of a serious wake-up call if they're willing to tolerate the kind of costly wastefulness that the Gartner report describes. Someone at your company needs to take charge at devise a strategy. Perhaps it's your CTO. Maybe you need to consider enlisting some new blood, such as a chief sustainability officer, to shake up the corporate culture. But you certainly can't afford to rest on your laurels, waiting around for some magic technology or formula to make everything better.

This, I think, is the real take-away here. Companies and agencies are made of people, so they often replicate all of the problems that people fall into, and habit is a monster. Taking the time to stop periodically reassess what you do on daily basis can be invaluable to the company, agency, or individual interested in sustainability. It doesn't have to be an always-on thing--that route takes you to neurosis. But there are a few big structuring decisions that you only have to make occasionally, and for most people, these are ripe for review.

ALSO: In other corporate environmental news, check out Yahoo's commitment to becoming carbon neutral.

Whenever I give our presentation on CES and on the clean energy plan, I always try to say that all forms of energy generation are problematic. While there is a ton that we can fairly easily do to reduce carbon emissions, we are still a ways away from having the kind of sustainable energy system that produces no burdens.

Last week, the New York Times offered two reminders. First, a recent study finds (unsurprisingly) that wind farms don't offset local air pollution (like smog and acid rain). This is where the engineered and accounting modes that dominate climate policies right now run into local realities.

Second, buses, particularly school buses, continue to spew pollution, despite the availability of retrofit technology. Of course, the problem is money.

The Regional Greenhouse Gas Initiative--the first coalition of states to pull together to cap greenhouse gas emissions, composed of New York, New Hampshire, Vermont, Rhode Island, Massachusetts, Maine, Connecticutt, Delaware, New Jersey, and Maryland--seems have to put its program into place, according to the New York Times. From what I can tell, it appears to be a fairly conservative cap-and-trade program. First, thankfully, it learns from the European experience, and it looks like most carbon credits will be auctioned, rather than given away. Second, however, it looks like it only applies to power plants. Third, they've strictly limited what other sources of carbon can be used for emissions credits. (And, though, it's never straightforwardly said, I assume that actually using renewable energy is okay, too. Presumably, that's considered a within-firm thing that directly lowers their carbon emissions, rather than something that has to be traded using the carbon credit.)

Anyway, it's interesting from a climate geek perspective, but the really nifty thing is the Times' interactive infograph, which has a map of power plant emissions in the region, a graphic to show how much carbon the plan cuts, and cute diagrams of the permitted activities for generating credits.

So, May is the National Bicycle Month. If you've been considering biking to work, or even to the grocery store or the gym, now's the time to start. There's the standard blah-blah-blah: healthy, good for the environment, fun--but what you're really thinking about is that you heard gas prices were going to hit $4 this summer. Even the Wall Street Journal is getting into the spirit, according to Triple Pundit, who provides a tidy summary of a recent glowing WSJ piece on bicycling. (You'll want to notice the "to be sure" moment when TP notes how many commuters in Amsterdam and Copenhagen cycle to work.) And Grist has some excerpts, and Biking Bis runs down some of the programs that Amsterdan and Copenhagen use to promote cycling. And back to Grist again: bike commuters are the happiest commuters (this is probably more a result of people choosing to bike rather than other modes, but still).

Biking Bis also points to a federal bill promoting bicycle commuting and how you can help support it.

Meanwhile, talking about bicycle sharing and pooled systems, Richard Layman points to the bicycles page of London's transportation agency, Transport for London, which sure is a beauty.

ALSO: On the other end of the transportation scale, why not a high-speed rail system for the midwest?

The 2005 Energy Policy Act (EPAct 2005, to those in the know) tasked public utilities to develop a handful of plans on specific topics, to be done by August 2008. The topics are pretty dreary sounding: net and smart metering, fossil fuel efficiency, interconnections, and fuel diversity.

CWLP has announced that on May 30 it will hold a public meeting to get feedback on its proposed plans for dealing with these issues. And I know: this sounds like warm death. But these meetings are one of the venues for citizens to decide what kind of future they--we--want.

Clean Energy Springfield is going to be reviewing CWLP's plans in the next few weeks. These plans are one of the major ways that CWLP decides how to promote or retard renewable energy and energy efficiency.

Net metering governs the rules for how CWLP buys energy from people who build their own renewables, like solar.

Smart metering--which I should say up front, CWLP is proposing to not really do much with--tries to better align the cost to produce energy with the rates we pay.

Interconnection deals with ... well, I'm not clear. I mean, it's how distributed generation (i.e., those solar panels I mentioned in net metering) gets into CWLP's grid. But I'm not clear on the issues surrounding this.

Fossil fuel efficiency deals with how CWLP can squeeze more electricity out of the chunks of coal it burns.

And the big daddy of them all is fuel diversification. This is CWLP's plan for reducing reliance on coal. Curious what it says? Go read it (PDF).

If you're at all interested in moving Springfield into a more sustainable future, drop me a line. We need help figuring out how to approach these plans.

Cleantech Blog has a rundown of some issues from a recent home performance conference, on getting home performance ratings to work. That is, how do you convey how green a home is during resale? This is definitely something that we'd like to see CWLP get into, since it enables a market response to differences in home energy performance. What if CWLP could do a basic assessment of a house's energy efficiency, and give you one number that made it easy to compare across houses, when you're shopping for a new home?

We already have a number of things you have to sign off on when closing a home. What if "house performance audit" was one of those things that you could legally demand from a seller?

And why not take it beyond just the energy used by the home itself? What if we could develop an accessibility measure that told you how accessible the house was to nearby services? That is, so many grocery stores with 5 minute radius and a 15 minute radius, that sort of thing? Simply by providing this information in a comparable format, you give people who value green homes the information they need to make the best choice.

Thirty-one states recently came to an agreement on monitoring major emitters of greenhouse gases. It's an important step to building necessary infrastructure for greenhouse gas caps. Thirty-one is a big number (well, out of 50, it's a big number), but follow the link and take a look at what states are involved--it's striking.

One of the slams against sustainable foods--local and organic or some combination of the two--is that they're the preserve of the wealthy, the upper middle class. Rebecca Blood is giving herself a challenge to see if that's the case. She's committing to live within the USDA's "thrifty food plan" (which sets a baseline for food poverty, and is used to alot food stamps) for one month, but keep her food as local and organic as possible. For a two-person household, this gives her $74 per week. What's more, she's doing it publicly, so you can see how she does.

The SJR carries a sad little piece by a George Mason professor of economics on ... climate change, gun control, and income taxes. I was at first interested to see how climate change and gun control work together, and how income taxes affect the both of them. But no, it's just about a paragraph and a half of "gotcha" editorializing on each topic. It's the most bizarrely unconvincing op-ed I've ever read.

One of the thorny issues of local food (and relocalizing in general) is rebuilding the institutions that support local food. Millers and marketplaces are both needed to have a vibrant, comprehensive food system, and they've mostly withered away, replaced with massively centralized steroidal versions of what once was. A few weeks ago, after the late frost snap, Casaubon's Book had a post about the trouble of food security (i.e., having enough food to eat, year after year) in a relocalized system. The whole thing is worth reading, but I was particularly interested in this bit, which gives a brief idea of the kinds of institutions we need to start building:

My proposition would be that local communities open food security centers, consisting of (ideally), a food pantry, a community kitchen for community canning and food storage, along with cooking classes, a cafeteria, and a food banking system and store.

If I can indulge in a little bit of self-publicity, a review I wrote of a Resources for the Future book called Scarcity and Growth Revisited has been posted at the Environmental Economics blog. At the end of it, one of the things I mention is that there's a burgeoning subfield of study called "time affluence," or the way that people's well-being increases more when they have lots of time than when they have lots of money and stuff.

I mostly let lie low the consumerism side of sustainability, but that's not because it's unimportant. Rather, it's maybe even more important, but also even trickier to get a handle on since you're dealing with people's hope, fears, aspirations, and identities.

One knock against a lot of the lifestyle sustainability issues that swirl around in environmentalism is that they're elite re-creations of older ways of doing things. I think this is true, to some extent, though not always for the reasons people think. (For instance, carey, in comments below, notes that you can't use food stamps at the farmers market.) Generally, though, I think that liberal and environmental elites have been in the vanguard of sustainability, and that's reflected in what sustainability is, as it's portrayed in the media.

But that "is" isn't what has to be. Conservative Rod Dreher wrote a book about "Crunchy Conservatives" (crunchy like granola; the origin of the book is probably this column in the National Review). That's a way into sustainability for conservatives.

Alternately, for the even more traditional-minded among us, The Two Income Trap offers a sustainability-friendly paen to the single-income family (based on the reasoning that one-income families are more resilient to economic shocks and more self-reliant).

With all of this in mind, and with the recent buzz about Bike to Work Day, allow me to point everybody to Take Back Your Time Day, which is October 24 this year. If you're interested in this sort of thing, I flipped through the book list at TimeDay, and pulled out a few that are available at our library:

Graceful Simplicity (decatur; requestable)
Living the Simple Life (Segal)
The Art of Doing Nothing (Vienne)
The Overworked American (Schor)
Simple Living Guide (Luhrs)

A few bits and pieces of news on global warming, plus a book recommendation. First, scientists appear to be warming projections. As, it further turns out, is the whole world, as less CO2 is collecting in the oceans around Antarctica, which means warming is going to happen faster than previously though.

Now for the book recommendation. It is not about global warming, per se. However, since all news points to more hotness, I thought I'd recommend Heat Wave, Eric Klinenberg's social autopsy of the 1995 Chicago heat wave. Heat waves are the real silent killers among natural disasters, killing more people than most other natural events. What comes out in Klinenberg's accounts is that it's not the heat that kills people, but the social disorder. In particular, he finds that community-oriented neighborhoods fared better than non-community-oriented neighborhoods, even holding constant relative poverty.

Neighborhoods are crucially important on a range of matters. Klinenberg's success is to show how they matter even in the case of a natural disaster. I think it's the case that our neighborhoods are going to dictate how well we respond to global warming. Both in terms of slowing and stopping it and reacting to the climate change that's already locked in. And this shows how, I think, there's nothing that we can do to fight global warming that doesn't also do something else for us.

Two big events this week: Tuesday night, Sustainable Springfield and CES are hosting a meeting with the Mayor Chris Koos of Normal. Mayor Koos shepherded in Normal's green building ordinance, which requires LEED certification for buildings over a certain size. The meeting and talk are at 7pm, Tuesday, May 29, at the Dove Conference Center at the Prairie Heart Institute. (For a PDF flyer, click here.)

Wednesday night, CWLP is holding a public hearing for five different standards that it's required to adopt or reject by the Feds. These standards, and the plans that will be set by them, can be an important tool in starting down a different energy path, one that prioritizes distributed, renewable generation of electricity. We'll be there, and I'll have a report later this week, along with CES's take on the standards (suffice to say, we think CWLP can do more), but if you're at all interested in where we go in the future, now is your chance to come and be heard.

The utilities committee passed on the second wind power contract to the full city council, without too much discussion. It's on the debate agenda; chairman Edwards said he was putting it on the debate agenda so that all of the new aldermen could have a crack at it. I missed the opportunity during discussion of the ordinance, but during the closing opportunity to address the committee, I had a chance to ask whether the contracts include a provision for purchases past the ten-year contract period (no). The committee was running late, so I was going to leave it at that, but alderwoman Simpson kindly asked for clarification of whether that meant I was against the contract, which gave me a chance to say, no, that I felt that this gave us an incentive to develop clean energy infrastructure within Springfield.

Following the utilities committee, CWLP held its hearing on five PURPA standards. (See their recommendations here.) I'll have more detail in the next few days, but I think the outcome is that the comment period will be open until June 21. The link to their recommendations includes information on how to submit comments.

I have no idea how CWLP staff took comments from CES, Sustainable Springfield, and Community Energy Systems (whose members and fellow travelers were the only people in attendance, save for one guy I didn't know, who--probably sanely--left early). I think they found us a bit oddball and feisty. My hope is that we've given them something to chew over.

However, we need more comments. I think CWLP is resisting seeing this as an opportunity to set rules that encourage renewable energy within Springfield, but it doesn't have to be that way. This is our utility, and if we want them to change what they do, we have to get out there and ask--we have to lead.

I said last night that I was going to take the next few days to outline what CWLP is proposing with their five standards. I wanted to start, however, by providing a little bit of context, in the form of an alternate vision for how Springfield can meet its energy needs, because I feel that it's only by stepping back and changing our ideas about what CWLP is for and how we use energy that the importance of these standards really starts to become clear.

Right now, we're on what Amory Lovins has called a hard energy path, characterized (on the electricity side of things) by high energy consumption and massive centralized electricity generation facilities. This path requires occasional massive public construction efforts, and has all of the problems typical of centralization and single-resource dependency.

The alternative is a soft energy path, which is characterized more by renewable energy resources, distributed across the landscape, as well as greater use of passive technologies (such as working with heat from sunlight, rather than against it) and heightened efficiency. This path meets changing energy demand in smaller increments, paced to those changes, rather than having to proceed in big clumps, with excess capacity slowly giving way to scarce capacity.

That's the pitch for a soft energy path as a smart infrastructure choice. The soft energy path, of course, is also a better fit for a world that needs to reduce its carbon intensity, as well as all for reducing all the other environmental problems that bedevil coal, natural gas, and nuclear power. Finally, the soft energy path is also a much more local path, prioritizing the energy that flows through Springfield's borders.

Literally decades ago, Lovins wrote a book about this, Soft Energy Paths, arguing that on just about every measure--from environmental performance to job creation and sustanence to financing--the soft energy path beats the hard energy path. (It's available through the Lincoln Library, though you have to request it from Decatur.)

One of the great things about Lovins' phrase is its recognition that these choices are a path, a route that we've taken, which has led us away from the other route. Our ability to today immediately adopt a soft energy path is limited. We don't have the infrastructure for it, we don't have the organizational support for it, we don't have the market mechanisms in place for it, we don't have the engineering standards we need to ensure that the system remains reliable and safe.

And that's what's at issue in the standards that CWLP is considering right now. Here's what they have to grapple with:

• Smart Metering
• Interconnection
• Net Metering
• Fossil Fuel Efficiency
• Fuel Diversity

Each one of those, save fossil fuel efficiency, is in some way crucial to developing a soft energy path for Springfield, through a combination of setting engineering standards, setting the economic rules that govern how people decide how and when to use energy and whether to install small-scale renewables, and--importantly--through goal setting.

I hope that I don't shock anyone when I say that CES is a tad underwhelmed by CWLP's position on these standards. Overall, I'd characterize what CWLP is proposing as tinkering around the edges with each standard, but without any real commitment to developing a robust alternative to what they do now. That shouldn't be surprising. As CWLP staff were consistent in pointing out, they have a lot of experience in utility operations (probably something on the order of 130 years experience among the members of each team that worked on each standard). They meant that to be impressive, and it is, but it's also an Achilles heel: they are used to a certain way of doing things, and lacking a sense of crisis or strong leadership, inertia is going to tend to drive them to keep on keepin' on.

CES feels that it isn't good enough. We feel that a soft energy path is preferable to a hard energy path, on its own merits, as well as because of the climate crisis and impending greenhouse gas regulations. (As an aside, President Bush is talking about setting carbon reduction goals by 2008. Caps on carbon emissions are coming, and soon. I'd be surprised if we don't get caps in place before the next round of aldermanic elections.) Even if you don't think the soft energy path is immediately preferable, I think most people would agree that laying the foundation that allows us to have the option in the future is a smart move.

But here's where my criticism of CWLP staff ends. While I think there's more room than they've shown for internal leadership on this issue, the real leadership, the real motivation for change has to come from us--Springfield citizens: CWLP's owners. This is our opportunity to lead, to tell CWLP where we want them to take us.

Last night, at the utility committee, that committee forwarded the ordinance approving CWLP's contract for the second wind power purchase to the full city council. These wind power purchases are for 10 years. Ten years from now, we will almost certainly be in the early stages of a post-carbon world. That means two things are going to be more expensive: coal-fired electricity generation and the wind power whose contract will be just ending. The time to develop an alternate source of carbon-free energy is now. Lovins has given us a vision we can use to get started. The federal government has given us something to coalesce around to start talking about that vision. CWLP has a proposal on the table. It's our turn to step up and make a decision.

Stay tuned for our comments on each standard.

Okay, I'm going to wimp out here and deal with the Interconnection (PDF recommendation) and Fossil Fuel Efficiency (PDF recommendation) standards together, since I have the least to say about them.

That said, the Interconnection standard in particular shows one of the problems with how CWLP is approaching these standards. At several points across some of the standards, staff indicate that they don't foresee much demand for interconnections, or smart metering, or net metering. What they miss is that CWLP has a choice other than passively acknowledging demand for this sort of participation: it can spur demand by encouraging interconnections, small-scale generation, and further fuel diversification.

Interconnection

Interconnection deals with the rules that govern how people can connect to CWLP's grid within Springfield city limits. There are safety and reliability issues with this, since proper installation and maintenance are crucial. As I understand it, CWLP is recommending adoption of two different engineering standards, based on the size of the generation unit. The smaller size (a 250 kVA limit) is up to about the size of neighborhood transformers that serve several houses. The larger size (a 1 MVa limit) would be up to about the size of a transformer that would serve a big box store. Beyond that size, CWLP wouldn't allow interconnctions. This sets, among other things, maintenance requirements on anyone who wants to connect to the grid.

Here's what we're looking at right now for CES's summary statement on the interconnection standard: We agree that CWLP should adopt this standard, and only request that the following issues be addressed in their recommendation to city council:

• Provide a sense of scale of the 250 kVA and 1 MVA thresholds.
• Leave open the possibility of developing standards for interconnections beyond the 1 MVA limit.
• Outline more explicitly what maintenance and tests will be required of small-scale generators, such as for homeowners and small businesses.

Fossil fuel efficiency

This standard relates to what measures CWLP intends to implement to make their coal-fired units more efficient. As I understand it, their recommendation is that they adopt this standard, because they're always looking for efficiency improvements, but that they're not committing to a particular plan (because it's always contingent on what the economics of the moment allows) or to particular efficiency gains (since those gains are often muddied by other factors that require CWLP to change how it operates, in addition to whatever infrastructure changes it makes).

We had no comments on this standard, which I'm sure CWLP was grateful for. We agree that they should adopt it, and trust them to be a good steward of squeezing what they can out of their coal.