Clean Energy Springfield

As mentioned below, FPL is the power provider that CWLP selected for its wind power. This post is just collecting together a few tidbits about FPL that came up last night, and that I've been able to find online. First of all, here's their generation mix: about half natural gas, slightly under one-third wind, eleven percent nuclear, and a mix of others for the rest. (No coal, unless it's in the 2% for "Solar and other.") According to the FPL rep last night, while wind accounts for slightly less than a third of their total capacity, it only accounts for 21% of their total electricity generation. Further, their 4000 MW of wind accounts for 34% of US marketshare of wind power; they are the largest wind power provider in the country (according to this 2003 slideshow, that's actually down from 43% that year). Here is a fact sheet about their wind power facilities.

Something that was mentioned in passing is that FPL only sells to municipalities. I can't find anything to back that up, and it seems somewhat incredible (particularly since it is not, itself, a municipal utility), so I might have misheard.

FPL, as the name suggests, is based in Florida. It's origins are in Florida Power and Light, a regulated utility. At some point, they got into the energy marketing game, and split off FPL Energy; they are now both owned under the umbrella of FPL Group. FPL Energy, with whom we're on course to deal with, has energy resources literally across the country. (At one point, I had a map showing all of their energy resources, but I can't find it now.) Sadly, they centralize operations of all of their national energy resources in Juno, FL. Their Juno facility runs 24 hours a day to monitor their facilities.

Our projects, as previously mentioned, are in Iowa. The first one is in Hancock County; the second is planned in Osceola, and it doesn't look like they've put a profile of it yet.

This is probably of interest to no one but me, but I'm going to explain a little bit of what I picked up from CWLP's presentation last night about how they picked FPL. They received 16 offers from 8 companies, many of which came with several pricing options: fixed costs across the lifetime of the contract, escalating (where it goes up a certain percent each year), and staired (which I didn't catch the explanation of--perhaps it only escalates every few years?). CWLP staff knocked out 7 projects, then worked with The Energy Authority to analyze the remaining 25.

The Energy Authority is essentially a co-operative effort of municipal utilities to pool resources and purchase expertise in energy marketing that would be too costly and intensive to purchase alone. What it seems they specifically did here was provide a strong modelling background for rigourously comparing the 25 offers. This took the form of stochastic modelling, which means running your model with random (though probabilistic) combinations of your key variables. What emerges, I believe, is essentially a likelihood determine of outcomes.

It sounds like the key variables that they were considering was climate (i.e., wind availability) and energy prices, based on the location of each proposal, and compared on a time-of-day basis. This means, if I'm understanding correctly, that they weren't comparing, say, the average cost price of electricity and the average amount amount of electricity the wind turbines would produce. They matched when the electricity would be generated to the likely price of electricity at that time of day. (Both wind patterns and energy price patterns have long datasets to back this up.)

In the final analysis that they presented to the committee, CWLP offered a chart of yearly projected market prices compared with the contracted price per megawatt. Included in this chart were two primary variables: the capacity factor (i.e., what percentage of nameplate capacity will the turbines produce at?) and the energy inflation rate. Capacity factor was listed at 26.3%, which seems low. There wasn't any discussion of this number, so I don't know if this is their best estimate or something more conservative. The energy inflation rate was 3.5%. As mentioned last and in the SJR, recent history puts the energy inflation rate at something more like 9%. And the higher that inflation rate, the better the return to the city, and the lower our bills will be.

Cleantech Blog has some information on Dell Computer's efforts to offer more green options. Neal Dikeman looks at two of their programs: Plant a Tree For Me, which plants trees as carbon offsets for the typical first three years of energy use for whichever model you buy, and some of their efforts to make computer use more energy efficient. (Sadly, he doesn't mention their takeback program for computers, which is one important way that, to my mind, they're leading their competitors--I may be a little out of date on this, though.)

Tree planting gets a lot of grief from environmentalists (who's the treehugger now, eh?), but I think overall this is a good start for Dell. As Dikeman notes, they don't yet offer offsetting for their operations (that is, for building the computer), and the piecemeal by-appliance approach doesn't strike me as particularly sensible (if I'm interested in offsetting my energy use, why not just offset my electricity bill? Is Amana going to be offsetting my refrigerator next?), but I can see it as an easy way to get the low-hanging fruit--people who'll do carbon offsets on impulse, but not stick with it month after month like you'd need to offset everything. (Why, if only there were some way to get billed for your offsets, right alongside your energy use? Gosh, that would be great. ;) )

Still, it's good to see them getting started on this. I wouldn't be surprised to see them get stung with the greenwashing tag. (And I just noticed that the first comment at Cleantech says that tree-planting efforts can get certified, which it doesn't appear that Dell is doing.) Still, it's easier to get someone who's made a commitment to do good than to get someone doing bad to do good, so I take this as a positive step.

ALSO: And I am more than ready for the day that computer makers compete on the basis of efficiency, rather than just brute computing power. Of course, with Microsoft ramping up its computing requirements whenever it fumbles a new version of Windows into the market, that's a hard sell.

In this post, I'm going to report a little bit about the questions asked by the aldermen in last week's committee meeting, because I think it's useful and kind of fascinating. I basically actually kind of enjoy their discussions. They take on a certain kind of performance art to me. Anyway, this is the last post about the committee meeting, unless other questions come up.

Chairman McNeil, Vice-chair Selinger, and committee aldermen Edwards, Kunz, Bartolomucci were there, as well as aldermen Strom and Yeager, who are not on this committee. Selinger, Bartolomucci, and Yeager did not, that I noted, ask any questions. McNeil only asked a few, Strom asked a few more, and Edwards and Kunz, as mentioned last night, were pretty aggressive in asking what seemed like mostly fair questions (which were sometimes rooted in misunderstandings).

I'm not going to cover every question, just going to hit a few that got the most discussion.

Early on, Edwards asked about the energy escalation rate. Specifically, he wanted to know what "our" escalation rate has been recently. Jay Bartlett said that it had been about 9% over the past 10 years. Kunz jumped in to clarify that Edwards and Bartlett were referring to different things. Edwards was asking about Springfield rates, which are set by city council, whereas Bartlett was talking about prices on the market. (Technically, I think, CWLP has to sell all of its power to the market, and then buy it back. This is costless, since we're selling to ourselves, but it means that they pay attention to those market rates, in addition to any time that they have to buy from the market because of plant down time.) There followed (and occurred again later) discussion of what would happen if the energy inflation rate were higher or lower than expected: higher means more revenue for the city and a negative fuel adjustment charge for ratepayers; lower means that CWLP has to cover the gap in some way. If it happens after Dallman IV (the new coal plant) comes online, any excess revenue from sales of excess generation to the market can cover it; if it happens before Dallman IV comes online (or if for some reason Dallman IV revenues can't cover it), the result will mean higher rates.

Second, McNeil asked why CWLP was proposing to start its purchase now. This was addressed again later when Kunz was confused by one of CWLP's charts, which showed revenue to the city in parentheses and red font, and costs to the city in black, which is the reverse of how you'd normally show it. This confused me, too--CWLP: if you're reading, don't do that; and also: the y-axes on all of your charts should be at zero: your chart of CO2 emissions for in-city electricity sales makes it look like we're cutting CO2 in half, when that's not nearly the case.

Anyway: the question about why CWLP wants to start now. First, apparently, the Hancock County energy comes at a good price. It's not broken out by Hancock versus Osceola, so I'm taking their word on that. Second, increasing demand for carbon-free electricity is driving wind prices up, along with wait times for building wind farms, so waiting longer will be more costly and take longer. Kunz asked why CWLP was presenting the two contracts separately, since they're interdependent. Bartlett said that they finished this one first, and figured there was no point in sitting on it. Also, he said they were getting a lot of requests to find out when the contracts would be ready. In particular, he mentioned that the State has started making CO2 reduction commitments, so they are eager for CWLP's wind power to come online, to show they're making progress.

Third, Strom asked whether the price in the next contract was already negotiated, and what it was. Bartlett said yes, and that it's the same price structure as this contract. Strom also asked when the second contract would start. Bartlett said that it would start when the Osceola farm came online, which is expected to be January 1, 2008. I didn't catch it, but Will said that someone said FPL is running ahead of schedule on that.

Fourth, there was some misunderstanding about the nature of our wind power commitment, asking whether we'd be in trouble if the wind didn't blow or, in the alternative, if our commitment could be filled early if the wind is particularly strong. Bartlett made clear that we've committed to the capacity, and we get whatever it generates.

Fifth, one point that CWLP's slide show contained was that FPL guaranteed an average of 90% uptime over a rolling 24-month period. So, if the wind turbines that we're licensing are down more than 90% of the time, FPL will pay a penalty to CWLP. Kunz asked whether CWLP put this in because they wanted to make money or because the Sierra Club required. Bartlett said that we want what the wind power provides (carbon reductions and protection from price fluctuations), so they wanted to make sure that CWLP got those.

Those were the biggest questions, according to my notes. Overall, I think these were good questions. It's clear that Kunz and Edwards don't want to do anything more than they have to, but I think their questions also reflected a concern for ratepayers. Personally, I'd prefer that concern be leavened with a little more foresight about the future and comprehensive view of CWLP's role. But Kunz, in particular, seems to be almost maniacally dedicated to what his constituents want, and you can't blame him too much for that.

It was not my intention to post this much today, but you go where the news takes you, right?

The bar got higher today, as Kansas City Power and Light reached an agreement with the Sierra Club and Concerned Citizens of Platte County, in which KCP&L agrees to certain conditions in exchange for those two groups dropping their objections against KCP&L's new coal-fired power plant. In fact! It's an agreement that "can serve as a model for environmental groups and utilities working together"! Indeed!

In all seriousness, from the brief skimming I've done, it looks like the process out there has been much uglier--6 years long, to start with, with much more counter-suing and allegations that KCP&L had broke the law (violation of New Source Review).

From their webpage, it looks like KCP&L is an investor-owned utility serving Kansas City and 24 counties in Missouri and Kansas, with 500,000 customers and 4000 MW of generating capacity (75% coal--er, "lower cost coal"--unsure on what basis that percentage is).

The agreement calls for them to add 400 MW in wind energy, create 300 MW of energy efficiency (kind of an odd phrasing, but I like the focus on performance, compared with our agreement's focus on dollars spent), reduce carbon emissions by 20% by 2020 (at some point, I think I saw that one primary mechanism of this will be that they have to offset in its entirety the emissions from their new plant), and reduce emissions from the new plant and their older plants (I haven't yet compared their goals with our goals). They'll also look into upgrading or closing an older plant, work on a net-metering plan, and finance several other projects in Kansas City recommended by the KC Climate Protection Committee. (I should note at this point that, in addition to having a Climate Protection Committee, Kansas City has also signed onto the Mayor's Climate Protection Agreement.) The agreement, in its full legal glory, can be found here.

So, congratulations to the Concerned Citizens of Platte County, KCP&L, and the Sierra Club!

City council unanimously voted in favor of CWLP's proposed contract with FPL. There was not a whole lot of debate--alderman Edwards confirmed that the prices on this contract were the same as those for upcoming 100-MW contract; he also asked whether CWLP's anticipations of future revenue were the same between the two contracts (no, because the second contract is in a different location and across a timeframe). Alderman Strom asked what assurances there were that the prices in the second contract would be the same. Todd Renfrow said that there was a verbal agreement, and then clarified that if something happens with the second agreement, this one gets nullified as well. Alderman Selinger asked when the second agreement would be ready; Jay Bartlett said two to four weeks; they pulled up the representative from FPL, and he said two to three weeks, that they were in the final stages of drafting the contract, and that CWLP's outstanding concerns were minor. He also confirmed that the price structure was the same.

And that was it.

Representative Henry Waxman has introduced his Safe Climate Act into Congress for consideration. I think that it's the strongest bill floating around Congress right now, but also probably the best. As David Roberts in that Grist link notes, the strength isn't just in the ultimate greenhouse gas emissions limits (80% decrease by 2050), but that it's structured to have small decreases on a yearly basis. That makes it very predictable, and prevents companies from delaying and delaying until it becomes exorbitantly expensive to comply. What's more, those limits are for a cap-and-trade system, which will give a bonus to those businesses and *cough* municipalities that are ahead of the curve.

The basic set-up (the bill also includes subsidies for new technology, including renewables and energy efficiency) is that emissions would be capped in 2010 at 2009 levels. They'd then decline 2% a year until 2020, when they'd hit 1990 levels. From that point on, they'd decline at 5% a year until 2050.

From an electricity perspective, that means we're in pretty reasonably shape. When the emissions limits kick in, CWLP's emissions will already be at 1990 levels. We'll have prices for CO2-limited electricity locked in until 2017 and 2018 (when our wind contracts expire, if everything goes according to plan). That's seven years when we can be investing in the next wave of lowering our CO2 emissions--maybe more wind power, but maybe solar in Springfield, geothermal, and superefficient retrofits of our existing homes. (Surely, all new homes will by that time already be net energy generators, right?)

Now, CWLP has indicated that it intends to keep all carbon emissions reductions from its wind power for itself/us. However, since those reductions are what allow CWLP to meet its obligations under a plan like Waxman's, it can sell 100% of its new reductions in the carbon trading system. That makes it even cheaper to start investing in our alternative energy infrastructure now--laggards in other states will be in effect subsidizing us.

Of course, CWLP can't solve all of our problems: we use a lot of oil, too, as well as natural gas, and we consume a whole host of energy-intensive consumables (like December grapes from Chile). That's why we need to start planning for CO2 limits now. The energy plan has given us one vital headstart. Let's not squander that.

For your skimming pleasure, I present "Change is in the Air: Toronto's Commitment to an Environmentally Sustainable Future," that city's brand-spanking new combined climate action/air quality plan. There's an overview here, and some griping about how it's all hot air talk here.

From my almost surely industry-deadened perspective, this looks like an ambitious start, with plenty to fill in over the next forty years (the plan calls on Toronto to reduce greenhouse gas emissions by 80% by 2050). I'd like to point to a couple of things that I found pretty nifty.

First, it must be said that they have a strong base to work from. There are several "completes" and "implements" in their action section that suggest Toronto's going to have an easier job getting to their targets than a lot of other places. That's the virtue of starting early.

Second, it builds on local resources. It does so most explicitly when it promotes substitution of locally produced goods for imported ones. However, local resources lurk in other places, such as using its Local Large Water Body as a source of cooling energy.

Third, it's kind of tucked in at the end, but I find it interesting that it calls for direct engagement with existing neighorhood planning efforts, tying climate change directly into what they do. Given that compact development is an important strategy for reducing transportation emissions, and neighbors are a primary opponent of densification, that's an important step.

All in all, an interesting start, with ambitious goals. One thing that I'd like to see a little more strongly is a sort of environmental SWOT -- Strengths, Weaknesses, Opportunities, and Threats -- assessment, making explicit what tools the city has for reducing its emissions, and what obstacles its likely to face. In fact, not coincidentally, I think such an analysis would be a great thing for Springfield to do.

Dr. Podlasek, probably the most visible skeptic of the clean energy plan, after some of the aldermen, has a letter in today's Journal-Register raising a few questions about CWLP's contract with FPL for wind power. (See my exhausting previous posts on the contract: 1, 2, 3, 4, 5.)

Dr. Podlasek says that there are still some issues in the contract that need more explanation. Well, here goes. (I've included a copy of Dr. Podlasek's letter as it ran in the SJR after the fold, so you can judge for yourself whether I'm answering his concerns.)

First, Dr. Podlasek says that it's worrying that there's an undisclosed connection between CWLP's consultants in selecting the wind power provider (The Energy Authority) and the provider (Florida Light and Power, or FPL) they chose. I'm not entirely sure what he's referring to, but I assume it's summed up in this picture: The Energy Authority market footprint. I'm not entirely clear what "market footprint" means--CWLP described TEA as a consultant constituted by municipal utilities pooling their money, so it could mean "pool of potential clients." Regardless, FPL--being part of a municipal utility--is on the map (although they don't get on the super special "who we serve" page). TEA's role in this was to develop and run the combined climate/energy price models that determine how much electricity each proposal could generate and what price that electricity could be sold at, based on location, time of day, and date, and based on CWLP's specifications.

Is this a relationship that ought to have been disclosed? I can't say. However, to give you a little bit of context, at a Citizen's Club panel in January, Dr. Podlasek warned all assembled that we'd soon be sending all of our money to Citigroup Goldman Sachs*, an investment house that's betting big on wind power. It's not hard to imagine that that's the complaint we'd be hearing about, if CWLP had gone with an investor-owned wind power provider, rather than one linked to a municipal utility. Dr. Podlasek doesn't suggest how TEA might be acting improperly, nor what the relationship is between TEA and FPL might be. If it is simply that FPL is part of a municipal utility, and therefore within TEA's customer base, I'm not sure that's something to be overly concerned about.

Second, Dr. Podlasek suggests that CWLP is playing word games with "no rate increase" and the fuel adjustment charge. To anyone who sat through aldermen Kunz and Edwards grilling Jay Bartlett over the energy inflation rate and what conditions would cause Springfield rates to go up and what would cause them to go down, it would be clear that CWLP is not dodging around a distinction between rates and the fuel adjustment charge. The idea that the contract will be revenue neutral is CWLP's estimate, and they made clear that it could be revenue positive, but that if certain conditions occur, it could also increase rates.

Third -- "the agreement should link the purchased electricity from Florida Power and Light to the spot market of electricity where CWLP will be selling this electricity" -- well, I'm not entirely sure what Dr. Podlasek means. TEA's projections for the spot price did include the location of the wind turbines, so ... as far I understand Dr. Podlasek's concerns, I think that addresses them. I'm happy to hear if I'm misunderstanding, though.

Fourth, Dr. Podlasek asks whether this 20 MW contract locks us in to buying from FPL, regardless of the price. In fact, this has the contract exactly backwards: rather than locking in the next contract, this contract is void unless the next contract passes as well. Moreover, his concern about the rate in the next contract was addressed by CWLP in response to aldermanic questioning: the rates for the next contract are the same as for this contract. If they go up, city council can reject the 100-MW contract, and do away with the 20-MW one at the same time.

I agree with Dr. Podlasek that CWLP's low rates and foresight are a boon to Springfield's economy, and I'd go further and say that CWLP will be even more important to Springfield's future than it has been to its past. We diverge because I think that this clean energy plan is a smart investment in preparing for a post-carbon world.

* LATER: Just realized I got the wrong investment house Dr. Podlasek was concerned about. Struck out the wrong one (Citigroup) and put in the right one (Goldman Sachs). My apologies.

One of the difficulties in a whole range of environmental endeavors is the problem of activating general environmental commitments. That is, how do you translate a general kind of pro-environmental belief into specific actions and into political support that expresses itself as a firm constituency? There's a ton of research into different aspects of this, from how to design PSAs with environmental messages, to getting people to switch to alternate commutes or not litter. In looking at how to get people (specifically, business owners) to participate in a green pricing program, I read through a lot of this material, and sort of made up a few conclusions.

First, people live through habits and routines. These are recipes for getting through the day without having to re-evaluate your options everytime you're faced with alternatives. Certain options get closed out--people begin to not even see them anymore. In my own life, for example, I tend to shop at Lowe's and Ace for gardening stuff, just because that's where I'm used to going, they're near other places I go to, I'm familiar with their interiors--each of these things make Lowe's and Ace a little less mentally costly than more local alternatives.*

Second, beliefs, identities, and actions are interdependent: each can strengthen the other. A person can go about a resource intensive life with a few minimal environmental commitments (some basic recycling, voting for politicians with some level of environmental policies, etc.). The discrepancy between our actions and our beliefs (such as that between my belief in shopping local, and my persistently shopping at Lowes) is often taken as a sign of hypocrisy.

However, third, a more useful way to understand that discrepancy isn't hypocrisy, it's as an opportunity. And, particularly, it's an opportunity if you understand everything that needs to be overcome to change a habit or a routine. It's not just getting someone to recognize what they should do; you also need to help them overcome the informational barriers to acting on that choice: you have to make the better choice easier.

So, for example, in changing how people commute, you have to look at to what extent people understand the bus system. Do they know where the closest routes are? Do they know where the closest bus stops along those routes are? Do they know how to time leaving their house to make it to the bus stop? Do they know how to pay once they get onto the bus, or how to signal for the bus to stop when their end point comes? All of these are, in some sense, trivial, especially for regular bus users or for people very familiar with the bus system. (Such as, say, employees of SMTD--getting outside the expert perspective is always going to be troublesome.)

However, trivial as they may be, each one is a potential site of frustration. And unless their environmental beliefs are strong and active, people will avoid frustrating situations. And so when you're designing an intervention, you have to figure out how to provide just the right amount of information to get people confident about trying something and to get them into a frame of mind that says "This is do-able, this will get easier," so that they can overcome those frustrations.

One thing that CES is trying, as an intervention in this regard, are "I WILL" or commitment cards. These cards focus on a single action that a person can do, outlines why the action is good or how to achieve it, and asks the person to sign the card, making a commitment to accomplish whatever the goal is. For an example, here's the card for "I will take the bus:"

The card forces people to confront a decision that can help them live in line with their beliefs, and provides a little bit of mental activation to connect those beliefs with something out in the world. However, the card is just a little bit of it. Just as important is having someone on hand when the card is signed to talk the commitment over. Everyone will have different concerns about whatever the decision is, and having people available who can help answer those concerns is the primary mechanism for overcoming all of those first-time frustrations.

* I should say at this point that I'm extrapolating from minimal review here. Habitual actions are different from single major decisions, such as buying a home or major appliance or choosing to participate in a green pricing program.

One idea I've been kicking around that I think would be a useful attention-getting tool is to perform a greenhouse gas inventory of Springfield. This basically would be a pretty rudimentary way of figuring out what Springfield's carbon burden is--how much carbon we're putting into the air. (You can get the inventory for the State here.) It would also help us see where our biggest sources are, which gives us a starting point for figuring out where to cut. This is something we'll probably do eventually, but I'm impatient, so I think it would be useful to get started now.

Fortunately, the Rocky Mountain Institute has put together the Community Energy Finder, an online tool for doing something similar. The CEF is geared more toward identifying community-wide opportunities for energy efficiency and renewables. It takes a lot of detailed information, but it looks like they've done a good job of outlining exactly what they need and who we can likely talk to get each part. It's not something that you can do in a day, but with a couple of people breaking the work up, you could probably do it in a week or two. It mostly involves calling various city departments or organizations (like the Chamber of Commerce).

If anyone is interested in doing this, drop me an email.

Diane sent me this article about why carbon trading, like a cap-and-trade system, won't work to lower carbon emissions sufficiently, and that therefore we ought to embrace a carbon tax. I gave her a quick rundown of what I thought of the controversy, and then sort of blew her off with a conclusion along the lines of, "Hey, it's all good for us." I'm going to recapitulate my thoughts on carbon taxes versus cap-and-trade, and then explain why that initial response was off the mark.

The central argument of the link is that the cap-and-trade system in Europe was kind of a disaster, and that extending it worldwide will be extremely problematic. And that's true. When prices on the European carbon market crashed, it was definitely a setback. But that's because it was a poorly designed program. Polluters were able to game the limits, setting them too high; the market was also structured by allowing polluters to own the rights at the start, rather than having to purchase them. This gave polluters little incentive to actually reduce their emissions in the short term.

On the other hand, my understanding is that the economics (that is, the incentives) of a well-designed cap-and-trade program and a well-designed carbon tax are basically equivalent. You can get the same reductions through either one. However, the key there is "well-designed"--both programs require a good design, and both have major pitfalls. A carbon tax, for instance, requires getting the tax right, and there's something of a trade-off between control (i.e., being sure that you hit your reduction goals) and simplicity (cap-and-trade has an enormous administrative overhead that a tax wouldn't have). A badly designed tax, however, will either underperform or be too costly--and the former is likely to lead to an abrupt swing toward the latter. In other words, that control isn't just good for meeting goals, it's also good because it's more predictable for all involved. And if we're talking about reducing risk of climate change, it's a bit silly to then insert a lot of risk over how the carbon market is going to work on a year to year basis. (This assumes, of course, that a cap-and-trade system can leverage sufficient incentives to make reductions go smoothly.)

As I said above, my initial conclusion for Diane was basically "Springfield is in a good place regardless of what the feds choose to do." However, if we get a bad policy, we get a bad policy, and that's that, regardless of whether it's a cap-and-trade or carbon tax. So, I'd amend that to say that when the feds really get down to haggling over different climate change plans, we have to be ready to weigh in in favor of quality programs. Businesses know they can game the system, and someone has to resist that.

David Roberts at Gristmill has some carbon tax updates--apparently, it's catching on with everyone who doesn't make the decision! One thing to add is that, since a lot of the aversion to a carbon tax is simply based on an aversion to any tax increase, a grand bargain in the mode of Gore's call to switch all social insurance taxes (FICA, Medicaid) over to a carbon tax might be workable. The downside is that one of the benefits of the tax as a new tax is that you get to spend that money, preferably on stuff that makes the transition easier--subsidies for decarbonized power and public transportation infrastructure, for instance. And one important thing to note is that smartly spent money can have effects far greater than just what you pay for. You can attach strings (to ensure that transit spending is supported by transit-friendly land-use regulations, for example) and you can leverage money (either by requiring matching funds or by funding high quality program or planning design, with implementation paid for by another source).

When he testified before Congress the other day, Al Gore talked, in part, about creating a smart energy infrastructure to really leverage the potential for distributed generation. Don't know what that means? Me neither. So go read about it.

The SJR editorializes in favor of voting today, upholding the noble journalistic tradition of hectoring citizens to not be so lazy. I'm a structures kind of guy, so I'm always more curious about how people's choices--such as whether to vote or not to vote--are shaped by their circumstances. For example, the State gives the day off for the statewide election--does it for Springfield's election? Are other employers in the city willing to let employees duck out for a little bit of time to go vote? Do employers promote voting?

A couple of years ago, Louis Menand wrote a great article for the New Yorker about all of the things, other than an interest in politics, that drive voter behavior. Button color and weather, for instance. Obviously, there is a lot that political candidates and parties do to promote or depress voter turnout. Maybe, though, there are more things that we can do as a community to promote it as well. What if the SJR told us about that? What if the city clerk started a community campaign for voting? Those, I think, would be more valuable than another hectoring screed about how if you don't vote, you don't get to complain.

ALSO: This is actually my main reason for posting: Missouri City ward election draws ZERO votes. Not even the guy running (unopposed) went out and voted for himself. FRANK EDWARDS: THIS COULD BE YOU: REMEMBER TO VOTE!

I was in Ann Arbor this weekend, and came across a new campaign there: Think Local First. It turns out that this is part of a larger campaign from the Business Alliance for Living Local Economies. Local economies are hugely important for connecting sustainability issues to actual quality of life--because local business shapes the local environment, because work shapes a big part of your life, and because the economy is an extension of nature. (Via Richard Layman, I see that BALLE is having their annual conference at the end of May--it would be great if someone from Springfield could go--I don't care who: someone from city planning, Downtown Springfield, Chamber of Commerce, anybody!)

One useful thing about bolstering the local economy is that, over time, you can push them to become more like an ecosystem, growing around the waste streams of other local businesses. (This is one of the themes of Bill McDonough's work, which is featured in Power Shift, showing Wednesday evening at the Lincoln Library, at 7:00.)

Charlyn Fargo*, who is, I guess, the SJR's agribusiness editor (according to her bylines on the State Fair and rodeo stories that come up on a google search for her), has a column up today advocating the re-election of Mayor Davlin. I'm trying not wade into the thorny issue of promoting candidates--I only want to talk about the policies. A couple of sentences in her column jumped out at me though, and I just have to question them:

His crowning achievement is the power plant. The only thing Springfield will likely regret about its new power plant is that it decided not to build a bigger one. Also, not long ago, the utility was reeling after losing tens of millions of dollars on a dicey power trading deal gone bad, and CWLP's coffers were still serving as a bottomless piggy bank for the rest of city government. Under Davlin, the utility is back on its fiscal feet and a cap has been placed on CWLP funding of the city budget.

I left the whole paragraph there so you could see where Fargo was heading with those two bolded sentences. I don't dispute that a fiscally healthy CWLP is a good thing. I'm not so sure, however, that in the future our only regret will be that CWLP didn't build a bigger power plant. Perhaps we'll regret not doing more to shift away more quickly from carbon-intensive forms of energy. Perhaps we'll regret not doing more to invest in an infrastructure that uses the energy within Springfield's borders. No, of course not--only silly hippies would think a thing like that. (Silly hippies like ... ConocoPhillips, a major oil company which has joined the ranks of other silly hippies like Alcoa, Duke Energy, Caterpiller, BP, and DuPoint in calling for mandatory caps on greenhouse gas emissions.)

Sadly, anything I more could say here would be trying to kill a gnat with a Buick--these are two toss off lines, and I doubt Fargo really has any sense of what she means, other than bigger and more are always better. There's no sense of what preparing for the future really means, or the many different ways in which we can meet our energy needs. Nope, we can just keep on keepin' on.

* UPDATE: I checked back a little later to see what comments on the op-ed were like, and found that the SJR removed Fargo's byline and left it as just the SJR's opinion.

And, of course, the day wouldn't be complete without me remonstrating you to go out and vote. So go do it.

Of course, maybe you're a saint, like me, and you would've voted without my stern order. So go read about why voting isn't enough for a strong civil society, or about problems that plague public participation efforts (such as, I don't know, CWLP's community energy meetings?), even when they strive to be reflective of the community at large.

SustainLane has put together a list of the top 10 cities (sadly, only out of the 50 largest cities in the US) based on the proportion of their electricity coming from renewables. Surprisingly, Oakland, CA, clocks in at the top with 17%, and Chicago comes in at ten (really, eleven, because there's a tie for 2nd) with 2.5%.

If you're familiar with the clean energy plan, then, you'd know that when we get our full complement of wind power, Springfield is going to beat the top performer, with our 20% versus Oakland's 17%. Even if you exclude the state's portion, we tie Portland for third, with 10%.

Of course, none of these cities are going to stop moving forward, and Springfield shouldn't either. We can increase that percentage in two ways: first when CWLP opens up it's green power program (wherein residents and businesses can choose to buy more renewable energy, for a slight increase in cost), and second by reducing our overall energy use--since our wind power commitment is for a set capacity (120MW), any decrease in our overall electricity consumption will get reflected as an increase in the proportion of our electricity coming from wind.

Obviously, we're not doing this so we can top someone's list (especially, when that person restricts the list to the 50 largest cities in the country). But it's always nice when you can ratchet the right thing to do to a little virtuous competition.

I wish I could promise that this will be the most boring post you're ever going to read on this blog. Sadly, however, my capacity to be boring has as-yet unplumbed depths. This post's sole saving grace is that I'm going to talk about $30 million.

At last week's community energy meeting, Jay Bartlett, chief engineer at CWLP, mentioned that within the past few weeks, CWLP went to New York to issue the second round of the municipal bonds that fund the construction of the new power plant. (See! I told you it was going to be boring. But just wait--it gets unboring in a minute.) Apparently, what they do when this happens is they do some sort of presentation to investors and, in particular, the two big bond-rating houses (Moodys and ... someone else? these are the groups that grant A or AA or B status to bonds, which is an indication of how risky they are) about why we're a good place for investors to put their money. Municipal bonds are not flashy performers--they're one of the low-risk, low-performance places that you put your safe money. (NOTE: I am not a financial expert. I keep all of my money in the garden.)

So CWLP talked with the money people for a couple of hours. In Bartlett's words, about half of the time was spent talking about the clean energy plan. At the end, they opened the bond up, and it was instantly oversubscribed by a factor of four. That means four times as many people wanted to buy in as were able to. So, CWLP closed the bond down, and reissued it with a lower interest rate. (This seems like cheating to me, but I'm sure that's because I keep my money in the garden.) Anyway, even at the lower interest rate, the bond was still oversubscribed by a factor of four. Bottom line: People really want to give us money.

No, I'm kidding, that's not the bottom line. The bottom line is that lowering CWLP's interest rate on these bonds works basically the same way as lowering the interest rate on your mortgage: your monthly payment is less, and at the end of your mortgage, you've paid less in interest. Where does that leave CWLP?

Paying $1 million less on the bond per year over its entire 30-year lifetime. Which means that CWLP is saving the city $30 million on the coal plant.

Now, I would love it if I could say that this is entirely due to the clean energy plan. However, investors don't give reason, so there's no way to know for sure. However, if you bear in mind that these investors are looking for a safe place to put their money, and you realize that the financial sector is coming around to seeing climate change, and associated regulations, as essentially one ginormous risk, it's not hard to see how the plan would have appealed to them, as it provides a healthy financial padding for CWLP against the costs of future greenhouse gas regulations.

But, whatever the cause, let's give CWLP a round of applause for getting us a better deal for our mortgage this bond.

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.

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.

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.

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.

Smart metering is more strictly known as "time-based metering," and refers to charging different rates depending on overall demand for electricity, which is strongly based on time and season. The amount of electricity used in a typical day is lowest overnight, rising to peak around five o'clock, and then declining back to that overnight trough. Because of the way that the engineering and economics of electricity generation work, the cheapest sources of power run the overnight load, plus that level (and then some) of the daytime load. When the cheapest source of electricity is running full-bore, then the next most expensive source of electricity is brought online. This keeps going until the oldest, clunkiest (and typically the dirtiest) sources of power are brought on only for the peak of the peak. What this means is that the cost of producing energy basically goes up and down with demand.

The grid, as a whole, works like this, with the electricity that goes into the grid priced at the cost of the most expensive producer feeding into the grid. We, as CWLP's customers, are not priced like that. This means that when costs are highest for CWLP (or for Ameren or Com Ed), we have no incentive (other than whatever persuasion CWLP wants to employ) to cut back our power use.

The key idea behind smart metering is that making consumer prices work a little more like grid prices is more efficient (since people can make better decisions, when the full costs of those decisions are factored in). Given that the costliest energy (of the on-demand generators, at least) also tends to be the dirtiest, smart metering can also be a tool for cleaning up the grid

Now, there are a few problems with smart metering. First, it's capital intensive--it means swapping out the meter you currently have with one that's much more complicated, which must either have enough memory to remember what your energy use was at different times of the day, or that has an always-on communications connection of some sort (a telephone line or an internet connection, such as through wi-fi). (And, logistically, this seems kind of like a nightmare, since in many cases the meter you have to swap out is in someone's basement, like mine.)

Second, some customers don't have much flexibility in adjusting their energy use, particularly those who struggle the most with their bills, like workers living paycheck to paycheck and the fixed-income elderly. (Of course, a vigorous and comprehensive energy efficiency effort would seems like it could alleviate this.)

Nevertheless, smart metering can be a useful tool, because it attacks the worst parts of the energy system, and it does so through price signals--that is, it's a tool that uses the market for virtuous ends. Moreover, in theory, it can be good for the utility by reducing the capacity needed for peak energy demand, and also by reducing transmission congestion. (I should say that, not being an electrical engineer, I don't understand the transmission congestion issue.)

(UPDATE: For further reaches of where smart metering can get us, check out this article from Grist.)

Now, that's my quick overview. If you want it in more detail (or if you don't trust me), take a look at CWLP's smart metering recommendation (PDF), wherein you'll see (1) actual graphs of CWLP's demand throughout the day! and (2) that I've been talking about smart metering as one thing, when it's actually three (time-of-use pricing, critical peak pricing, and real-time pricing). Also, I should point out that CWLP already has a very rudimentary form of time-of-use metering in place: seasonal pricing, where they have different rates for summer and winter.

Here's essentially what CWLP is recommending for this standard:

• Adopt one mode of smart metering for large commercial customers.


• Those customers must go through an engineering analysis to ensure that they can actually shift their demand.


• Re-analyze the CWLP's infrastructure costs, so as to bill that separately from energy use for these customers


• That there be at least 10 of these large commercial customers before starting the program.

CWLP recommends that they not adopt the standard in any form for residential customers.

Here, in a nutshell, are CWLP's concerns that lead them to these recommendations:

• Revenue neutrality: CWLP wants to ensure that customers pay for the services that they use, so they want to fund any smart metering program through the program participants. More importantly, however, they also want to ensure that customers who participate don't reap a windfall through the changed rate structure, simply because they already use power at off-peak times. They would lose revenue, without gaining any of the benefits of smart metering. To some extent, CES shares this concern [* see below the fold for some background on this].
• Capital cost: Starting a smart metering effort means, well, upgrading electricity meters, for one. But it may also involve putting a communications system in place. And it appears that it involves some sort of computer system upgrade for how CWLP bills these customers. CWLP feels that, comparing these costs against the benefits it would receive (peak load reduction and reduced transmission congestion