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.
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 proposed decision (“PD”) ignores the critical need to include efficiency and increased behind the meter solar capacity as part of holistic plans to decarbonize building, the PD includes some good proposals. The PD would have more funding 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. The PD importantly restricts 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 opposes 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.
Gas Planning: The CPUC has opened a proceeding to address issues of natural gas reliability and long term gas system planning. Wild Tree is glad to see that the CPUC has finally taken action to engage in planning for how California will move away from fossil fueled heat and power towards zero carbon systems but is concerned that the proceeding will result in something very different than needed – increased investment in gas infrastructure resulting in stranded assets and increased charges for community choice energy consumers, and increased reliance on stored gas at Aliso Canyon and elsewhere despite declining need for such gas.
- Wild Tree Comments on Order Institution Rulemaking – Unfortunately, the Order Instituting Rulemaking (“OIR”) indicates that the CPUC will not actually begin any work towards long term gas policy and planning until the end of 2021. This is impossible to understand and Will Tree hopes this plan will be quickly amended. The OIR also, disturbingly, seeks to reconsider the current CPUC policy that slack capacity for natural gas is not needed – meaning that there is no need to have extra storage of gas above and beyond what is estimated to be needed. A change in this policy would mean greater risk to communities and the climate from increased methane leaks during transport and storage of gas.
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.
As Wild Tree has advocated previously before the Commission: “The best way to decrease risk from power lines and maximize reliability is to not have them – transmission lines are unnecessary when power generation is local, distribution lines are unnecessary when generation is distributed and distribution lines in areas of high wildfire hazard can be built underground. The focus in rebuilding areas damaged by wildfires should instead be on incentivizing residential PV systems above and beyond the low floor established in Title 24, in building community microgrids for storage and power sharing, maximizing energy efficiency, and in developing other local, distributed renewable resource projects. This will serve to better protect these communities from future fires, protect them from de-energization and other reliability issues, and better enable them to respond to disasters in the area.” (R.19-01-011, Wild Tree Comments on Order Instituting Rulemaking (March 11, 2019).)