Great article in today's SJR, about CWLP's PURPA standards. Chris Wetterich did a pretty good job of grappling with all of the standards. There was one point in particular that I wanted to respond to, from Bill Murray, who is shepherding all of this stuff for CWLP.
"The group has trouble distinguishing between consideration of a standard or policy and implementation of a standard or policy through a particular program," Murray said. "It would be like trying to reap the crop before the seed has been planted."
The first time I contacted him, to ask about the process CWLP was going through, Murray made much the same point, and I like to think that we did a good job of respecting that sentiment in shaping our recommendations. We threw in a lot of extra stuff, to be sure, but that's because we're trying to argue what's possible.
That said, it's not clear to me where the line between adopting the standard and implementing the standard is drawn. In CWLP's own recommendations, many of their modifications look to me to be creeping into implementation, particularly where they talk about capacity limits. And, if you look at the transcript of the public hearing, page 9, you'll see that I asked what CWLP's plans were for implementing one of the standards (fuel diversity), and the answer was, essentially, "we don't know, we didn't think about it." (Not, obviously, a direct quote.) So, we decided to include in our recommendations guidelines for how CWLP should implement--not doing the work of implementation itself, but instructions that city council can take up guide CWLP. To take the fuel diversity standard again, where CWLP had no sense of what it would do next, we suggest that they conduct a planning process to meet a goal (replacing our wind power capacity with in-town renewable resources by the time the wind contracts end), and that they include their green power program in that planning. We're not looking to dictate to staff how to fill in everything, but we think it's appropriate for Springfield citizens and for city council to set goals.