Clean Energy Springfield

The fuel diversity, or fuel source reliance, standard deals with dependence on a single source of fuel for electricity. Currently, CWLP generates the vast majority of our electricity from a single source, Illinois coal. If CWLP adopts this standard, it commits to developing a plan to diversify its generating capacity. Diversity can be good for a number of reasons. For example, if your sole fuel source becomes more expensive, you have fewer options for coping with that increased expense than if one fuel source among many becomes more expensive. Of course, increasing diversity is also going to mean, to a large extent, increasing use of renewables.

CWLP staff recommend adoption of this standard, and in addition to their 2-page comment supporting that recommendation, they have also released a 29-page internal white paper, evaluating in greater depth some of the different options that were considered in developing that recommendation. Despite the concerns I'm going to outline below, I would recommend this to anyone interested in finding out a little more about how our utility operates. It doesn't cover nearly everything, but it's a good explanation of the generation side of things.

In recommending adoption of this standard, staff recognize that CWLP is heavily dependent on a single fuel source, and that construction of the new Dallman plant will increase the use of that fuel. They further say that future generation will be more diverse due to the upcoming wind power purchase. However, they fail to acknowledge the time limit on the wind power purchase: roughly, 10 years from now. Thus, the wind power will not diversify Springfield's energy sources in the long term: in 10 years and a day, our fuel source diversity will drop back to where it is now.

Of course, that wouldn't be problematic if they outlined a vision for increasing diversity during the time that the wind power purchase protects us from the likely future costs of greenhouse gas regulations. But they don't. They acknowledge that distributed generation will play a role in increasing fuel diversity, and in the white paper recommend that CWLP encourage the use of distributed renewables, but the commitment that comes through in the final staff recommendation is weak.

Moreover, given that renewables will show up in Springfield's energy supply as fixed amounts, any increase in energy efficiency, as well as the use of non-electrical renewables like geothermal heat pumps and solar water and air heaters, will in effect increase CWLP's fuel diversity, since they will lower the amount of energy supplied by CWLP's coal-fired generators. Including a stronger commitment to efficiency and these non-electrical sources of energy will mark a commitment to greater exploration of a soft energy path. Further, providing a target will help CWLP set priorities in encouraging these alternatives in the next ten years.

While we laud the white paper's suggestion that CWLP can promote net metering, we are concerned that this suggestion is out of step with the actual net metering recommendation, which appears to take a much more passive approach. We are also pleased with the white paper's suggestion that CWLP could install its own solar panels. Sadly, that suggestion does not quite make it into the recommendation for the standard. Worse, CWLP has already made a commitment to providing a green power option for its customers, wherein customers interested in green power can elect to pay more for it. Such a green power program can be a powerful tool for building local sustainable energy infrastructure in Springfield, yet is completely missing from all staff discussion of the fuel diversity standard.

Indeed, at the hearing, I asked the CWLP staff member presenting this recommendation what program development they expected as a result of adopting this standard. The answer was none. (Which suggests that the plan they'll develop will simply be whatever disconnected parts have to be done for the other standards, plus "keep on keepin' on.")

The other standards that CWLP has had to consider seem to me to be fairly specific in intent: they envision a particular program, with a well-understood way of operating, to be pursued more or less aggressively. This standard, on the other hand, is much more open. This gives it the potential to provide an overarching vision for electricity generation in Springfield. This can be where we declare that we want to find another way.

Of course, this goes beyond a simple "adopt" or "do not adopt" mentality. The way in which we adopt this standard can guide CWLP staff in how they approach the future. Should they be content to simply enable distributed generation, for example, or do we want them to actively pursue it? Should they focus on photovoltaics, or should they open themselves up to the remarkable diversity of energy flowing through Springfield? Will they have the time, opportunity, and money to do trials of new alternative energy sources. Consider this new design for hydropower: the gravitational vortex, a small turbine that works in a pool less than twenty feet across with a water drop of about 5 feet. Not only does it generate power, it also oxygenates water, and helps speed it along the path to biological purification. Even short of actually installing such a thing somewhere in our area, does CWLP's recommendation envision staff devoted to monitoring such developments and evaluating them for potential use?

Therefore, Clean Energy Springfield agrees in the staff recommendation that this standard be adopted. However, we make the following requests:

• CWLP should commence a planning process to identify how the community wants to pursue fuel source diversification. This should focus heavily on innovative ways of encouraging public involvement, and should work in sync with CWLP's existing community outreach efforts.
• CWLP should acknowledge the role that its green power program can play in developing long-term renewable energy infrastructure within Springfield.
• CWLP should include non-electrical renewables, such as solar water and air heaters and geothermal heat pumps, and energy efficiency in its estimation of future fuel source diversification.
• CWLP should recommend adopting goals for fuel source diversity, in categories covering net metering, green power development, CWLP's own trial experiments, energy efficiency, and non-electrical renewables. These goals should be one result of the planning process outlined above.