The climate crisis is the most pressing issue of our time and we must take immediate and decisive action to reverse our current trajectory. But, such action must be undertaken through holistic and sustainable means. In regards to the energy sector’s contribution to climate change, Wild Tree Foundation advocates for the development of holistic and sustainable energy programs with a focus on decreased use of fossil fuel and decreased greenhouse gas emissions; decreased consumption and increased efficiency; reliance on local, distributed renewable resources; and protection of human health, wildlife, and wild lands.
Wild Tree Foundation also advocates for a greater focus on the contributions of industry and agriculture to greenhouse gas and other hazardous emissions. Decreased consumption, a shift to plant based diet and elimination of concentrated animal feeding operations, and the decrease and eventual elimination of oil and gas extraction are all critical components of any sound plan to address the climate crisis.
Distributed Energy Resources Grid: CPUC Proceeding R.21-06-017 rulemaking to address needed changes to the grid to accommodate a high distributed energy resources (DER) future. This proceeding presents an opportunity to move California in the right direction of increased penetration of DERs but also could result in a strengthening of the status quo whereby the private, investor-owned, for-profit utilities wield oversized influence over our grid. Wild Tree has partnered with the California Alliance for Community Energy for its advocacy in this proceeding.
- Wild Tree Comments on OIR: Wild Tree fully supports the stated goal in the OIR of “preparing the grid to accommodate what is expected to be a high DER future and capture as much value as possible from DERs as well as mitigate any unintended negative impacts” but the proposed rulemaking would not lay the proper foundation for this proceeding and would not allow for sufficient stakeholder involvement which must be a priority.
- Joint Reply Comments on Engaging Environmental and Social Justice and Other Vulnerable Communities
Building Decarbonization: CPUC proceeding R.19-01-011 rulemaking to implement SB 1477 BUILD and TECH programs – programs that provide funding to speed market transformation for technology, such as heat pumps, that can assist in decarbonizing buildings. Wild Tree is a rare voice against thoughtless building electrification that, if done wrong, will result in an increase in GHG emission as electricity load is increased. Wild Tree is advocating for holistic and sustainable building decarbonization programs that incorporate efficiency and increased installation of larger rooftop solar systems to prevent electrified buildings from increasing electricity load.
- Wild Tree Comments on Staff Proposal – This proceeding should focus on developing programs and policies that pair electrification with measures to increase efficiency and installation of greater capacity solar PV systems. The life cycle of replaced and replacement appliances must be considered.
- Wild Tree Reply Comments on Staff Proposal – Program focus should be on making the most efficient technologies available and affordable, and on decreasing installation costs.
- Wild Tree Comments on Proposed Decision and Reply Comments – While Wild Tree is disappointed that the CPUC’s decision ignores the critical need to include efficiency and increased behind the meter solar capacity as part of holistic plans to decarbonize building, the decision included some important elements. More funding will be dedicated to TECH on the grounds that it will be much more difficult to decarbonize existing buildings than new building; sets aside the majority of funds for disadvantaged communities and low income recipients; and includes life cycle of replaced and replacement appliances as a factor in avoided GHG emission metrics. Most importantly, the CPUC has restricted incentives for appliances, such as heat pump water heaters, that use high global warming potential (“GWP”) refrigerants. Wild Tree continues to be the lone voice for the need to focus on increasing the market for low GWP refrigerants electric appliances given the significant contribution that high GWP refrigerants make to building GHG emissions.
Waste Methane: CPUC proceeding A.19-02-015 SDG&E application for a “green” tariff for “renewable natural gas.” Wild Tree opposed SDG&E efforts to market waste methane as some sort of renewable, green alternative to natural gas and to import waste methane through the natural gas pipeline system. Methane is a potent GHG that poses great risk to our climate, and human and environmental health regardless of its source. Instead of seeking to create a market for waste methane from manure, trash, and waste water, we should be focusing our efforts on decreasing the creation of waste methane at the source. This should include efforts to increase plant based eating, utilization of unpreventable waste methane at its source for local power generation i.e. waste treatment plant, and municipal composting and waste diversion programs.
The CPUC ultimately approved a “green” tariff for SDG&E although it significantly modified the proposed tariff for the better based, in part, upon Wild Tree’s advocacy.
- Wild Tree Opening Brief, Reply Brief, and Comments in Opposition to Settlement Agreement – Wild Tree argued that the Application was no more than a meritless, half-baked attempt to establish a program for utility procurement of pipeline-injected biomethane prior to the Commissions promulgating rules regarding utility procurement of biomethane pursuant to SB 1440. Under the proposed program, the Applicant utilities would seek to circumvent the requirements of SB 1440 that biomethane procured by the utilities enhance California’s environment and the proposed program would be harmful to the environment.
- Wild Tree Comments on Proposed Decision – Wild Tree opposed the decision approving, with modifications, a settlement agreement that SDG&E reached with its allies over objections of Wild Tree and other environmental advocates. The decision did improve upon the settlement by requiring 50% of waste methane to be sourced from California and the rest to meet the requirement of SB 1440 that it demonstrate environmental benefits. The program will still be harmful to efforts to decrease methane pollution and thus, ultimately, will hinder efforts to address the climate crisis.
Microgrids and Grid Resiliency: CPUC proceeding R.19-09-009 to set a policy framework on the commercialization of microgrids pursuant to Senate Bill 1339 and to address approaches to increasing resiliency in the electric grid especially in regards to PG&E power shut-off. Wild Tree supports the growth of the use of microgrids throughout California, especially in high fire danger, rural areas dependent on lengthy transmission lines, and disadvantaged communities. Wild Tree is optimistic that this proceeding will result in growth of the use of microgrids and a resultant positive impact on our climate, environment, and communities but is concerned that the IOUs, especially PG&E, will attempt to utilize microgrids as a way to enable continued reliance on fossil fuels.
Unfortunately, the CPUC has approved a proposal by its staff that fails to meet the statutory mandate that it act to commercialize microgrids. In effect, the CPUC would continue to rely upon the IOUs to set up microgrids even though the IOUs have been the largest impediment to proliferation of microgrids, especially community microgrids.
- Wild Tree Comments on Staff Proposal – “The Staff recommendations miss the mark in many respects in addressing what should be the overarching goal of Track 2 – the widespread, expedited deployment of permanent (not pilot), non fossil-fuel microgrids with a focus on vulnerable communities subject to IOU uni-lateral power shut offs. . .The Staff Proposal and recommendations will not facilitate the commercialization of microgrids and should be reworked to provide needed expansive changes and measurable targets for fast, widespread microgrid deployment so that we can begin immediately benefiting from the reliability, resiliency, public safety, health, air pollution, and climate benefits non-fossil fueled microgrids can provide.”