Rulemaking: R.20-11-003 Exhibit No: ______Date: September 1, 2021 Witness: Joel Yu Commissioner: Marybel Batjer ALJ: Brian Stevens and Sarah R. Thomas
PREPARED TESTIMONY OF JOEL YU
ON BEHALF OF ENCHANTED ROCK, LLC TABLE OF CONTENTS
Page
I. Introduction ...... 1
II. Detailed Recommendations ...... 3
A. Duration ...... 3
B. Justification that Policy Will Provide Reliability Benefits During Net Peak ...... 4
C. Policy Impact – Megawatts Available ...... 5
D. Implementation Requirements ...... 5
E. Potential Risks ...... 6
F. Regulatory Justification ...... 7
III. Conclusion and Verification ...... 9
EXHIBITS
Exhibit 1 Statement of Qualifications of Joel Yu Exhibit 2 Excerpt of Hidden Grid: More Than Eight Gigawatts of Fossil Fueled Back-Up Generators Located in Just Five California Districts Exhibit 3 Overview: Bay Area Backup Diesel Generation Exhibit 4 CEC – Alphabetical Power Plant Listing Exhibit 5 Excerpt of Decarbonized Resilience Assessing Alternatives to Diesel Backup Power
i 1 I. INTRODUCTION
2 1. Q. Please state your name for the record.
3 A. My name is Joel Yu.
4 2. Q. On whose behalf are you testifying today?
5 A. I am testifying on behalf of Enchanted Rock, LLC (“Enchanted Rock”).
6 Headquartered in Houston, Texas, Enchanted Rock provides affordable, long duration back up
7 power to commercial, industrial, and institutional customers across the country and expects to
8 operate resilience microgrids in California within the near future. Enchanted Rock has
9 commissioned nearly 400 MW of dispatchable distributed generation and resiliency microgrids
10 with over 100 MW under construction and has covered 4,400 hours of outages. Enchanted
11 Rock manages the design, construction, commissioning, operations, and maintenance of natural
12 gas and renewable natural gas-powered technology so utilities and end-use customers have
13 access to reliable back up power and demand response (“DR”) capability without the expense
14 and challenges that come with maintaining a back up generation system. With experience
15 building and operating over 120 installations that operate in grid synchronous and island modes,
16 Enchanted Rock has a deep understanding of the technical and market challenges of microgrid
17 development for DR and resiliency. Enchanted Rock has collaborated with utilities, regulators,
18 and market operators alike in developing market conditions conducive to resiliency microgrid
19 development.
20 3. Q. Please describe your experience and qualifications.
21 A. In my current role as Director of Regulatory & Legislative Affairs for
22 Enchanted Rock, I have been engaged in several California Public Utilities Commission
23 (“Commission”) proceedings, including the Microgrid proceedings, Integrated Resource Plan
24 proceedings, and Distributed Energy Resource proceedings, to propose helpful reforms to
1 1 address California’s energy resilience crisis. Prior to Enchanted Rock, I worked for
2 Consolidated Edison Company of New York (“ConEd”), representing the utility in PJM and
3 NYISO wholesale market stakeholder discussions and at the Federal Energy Regulatory
4 Commission. In my early career for ConEd, I worked as an Operating Supervisor over
5 distribution network system operations, maintenance, and construction work. I have a
6 bachelor’s degree in Chemical Engineering from Columbia University and an MBA from New
7 York University. A copy of my CV is provided as Exhibit 1.
8 4. Q. Have you previously testified before the California Public Utilities 9 Commission (“Commission”)?
10 A. No. However, I have testified on behalf of Enchanted Rock before the
11 Texas Legislature.
12 5. Q. Please summarize the principal recommendations of your testimony.
13 A. Demand response has the potential to play a significant role in maintaining
14 grid reliability and furthering California’s decarbonization efforts. In recognition thereof,
15 Governor Newsom ordered the Commission to expand and expedite approval of DR programs
16 in his July 30, 2021 Emergency Proclamation.1 Accordingly, the Commission should modify
17 the existing Base Interruptible Program tariffs to allow the temporary use of currently
18 prohibited back up generation resources to support DR activities. Concurrently, the
19 Commission should establish an incentive program to encourage cleaner, carbon-neutral fuels
20 for future back up generation resources and facilitate converting existing fossil-fueled back up
21 generation to renewable fuels.
1 See https://www.gov.ca.gov/wp-content/uploads/2021/07/Energy-Emergency-Proc-7-30-21.pdf.
2 1 6. Q. How is your testimony organized?
2 A. My testimony is organized in accordance with the Staff Guidance issued
3 by Administrative Law Judge Brian Stevens on August 11 as it relates to “modification to an
4 existing policy that could reduce demand or increase supply at net peak.”2 Accordingly, I
5 respond to the following six criteria designated in that ruling:
6 a. Duration – temporary or permanent, 7 b. Justification or demonstration that policy will support the delivery of reliability 8 benefits during net peak, 9 c. Estimate of policy’s impact (MW), 10 d. Implementation requirements, including whether other state agencies or CAISO 11 must approve, 12 e. Potential Risk of proposal, and 13 f. Statutory and/or regulatory justifications and history.
14 II. DETAILED RECOMMENDATIONS
15 A. Duration
16 1. Q. Describe the timing and duration of your proposal.
17 A. My proposal would initially and temporarily suspend the existing
18 prohibition against using fossil-fueled back up generation to support DR programs, particularly
19 the Base Interruptible Program (“BIP”) currently offered by utilities, in recognition of the
20 state’s emergency electricity supply needs. The use of fossil fuels would only be allowed
21 through the summer of 2022. Consistent with Senate Bill (“SB”) 1339, which mandates
22 encouraging clean microgrid development,3 I recommend that the Commission require that
23 generation resources that wish to continue participation in these programs for 2023 and beyond
24 must:
2 See August 11, 2021 E-mail Ruling Providing Staff Guidance on the Contents of All Program Proposals Submitted in Opening Testimony by Parties to This Proceeding, at 7. 3 Microgrids are relevant here because the likely technologies to displace diesel backup generation not only operate in island mode when the grid is in outage, but also in grid synchronous mode to provide support to the grid when needed.
3 1 1. meet the California Air Resources Board (“CARB”) Distributed Generation 2 (“DG”) Certification requirements for local emissions,4 and
3 2. run on California Energy Commission (“CEC”) Renewables Portfolio Standard 4 (“RPS”)-certified and/or CARB-certified renewable fuels.
5 2. Q. How would the Commission incentivize customers to replace existing 6 diesel back up generation with cleaner generation resources that meet 7 the CARB DG emissions standard and run on CEC RPS-certified 8 and/or CARB-certified renewable fuels?
9 A. Upgrading equipment will require significant capital investment. To
10 facilitate this investment, the Commission should:
11 1. set a price floor at the current compensation rate of at least ten years upon 12 conversion for generators participating in the BIP; and,
13 2. exempt demand resources backed by dispatchable distributed generation from 14 the DR reliability cap.
15 B. Justification that Policy Will Provide Reliability Benefits During Net 16 Peak
17 1. Q. How does the proposal support the delivery of reliability benefits 18 during net peak?
19 A. The proposal allows the Commission to easily measure the delivery of
20 reliability benefits during net peak. The amount of DR capacity available from back up
21 generation is simply the amount of back up generation turned on or the actual amount of load
22 reduced in response to dispatch instructions. Because much of this back up generation would be
23 sited at high-load factor installations like data centers, the DR capacity could be easily
24 determined, and the impact accurately measured. Accordingly, the “DR reliability cap”
25 established in D.10-06-034 and the recent update in D.21-03-056 should not apply to DR
26 backed by dispatchable distributed generation.
4 See Cal. Code Regs. tit. 17, § 94201 et. seq. and CARB’s Certification Regulation, finalfro AMENDMENTS TO THE DISTRIBUTED GENERATION CERTIFICATION REGULATION.
4 1 C. Policy Impact – Megawatts Available
2 1. Q. How much potential capacity relief may be available from this 3 program?
4 A. Over 8 GW of back up generation is in place across the South Coast, Bay
5 Area, Eastern Kern County, San Joaquin Valley, and Ventura County.5 Additionally, new
6 installations totaling 1,500 MW of back up generation are currently under development in the
7 Bay Area6 and over 800 MW of this amount is currently under consideration in the CEC’s siting
8 process.7 Given the vast quantity of back up generation that may participate in the BIP program
9 with the proposed 10-year contract and price floor, it is sensible to exempt DR resources backed
10 by dispatchable distributed generation from the DR reliability cap.
11 D. Implementation Requirements
12 1. Q. What are the implementation requirements of the program?
13 A. Implementation is straightforward. First, the existing prohibition from
14 using fossil-fueled back up generation to support BIP curtailments would be suspended through
15 summer 2022, in recognition of near-term emergency supply needs in the state. Second,
16 generating facilities seeking to participate in BIP for 2023 and beyond must comply with the
17 CARB DG Emission standards and convert to an approved renewable fuel supply. Third,
18 customers committed to convert from diesel to approved renewable fuel supply would be
19 offered an incentive of a ten-year contract with a price floor at the current market rate for BIP
5 See Exhibit 2, Steve Moss & Andrew Bilich, Hidden Grid: More Than Eight Gigawatts of Fossil Fueled Back-Up Generators Located in Just Five California Districts, M Cubed (May 2020), at 6 (Table 3), BUGs-in-5-CA-Air-Districts.pdf (lgsec.org). 6 See Exhibit 3, Slide 3, https://efiling.energy.ca.gov/getdocument.aspx?tn=236425 7 See Exhibit 4. See active data center applications at the CEC website for power plant licensing applications: Alphabetical Power Plant Listing.
5 1 effective upon conversion. These new DR resources should not be counted against the existing
2 DR reliability cap to the extent they are backed by dispatchable distributed generation.
3 E. Potential Risks
4 1. Q. What are the potential risks of this proposal?
5 A. Market prices and incentives are insufficient to drive near-term capital
6 investments to replace diesel. Accordingly, the proposed ten-year BIP contract term with the
7 price floor is needed to mitigate this risk and incentivize conversion. The following information
8 suggests the relative costs and provides an estimate of required incentives.
10 Year Financial Cost ($/kW-Emergency Standby Power) $1,000 Market $800 $101 Revenue $121
W $600
k $520-600 / $400 $ $101 $750 $575 $200 $350 $0 Tier 2 Diesel Tier 4 Diesel RNG-Fired Reciprocating Engine
Capex O&M NPV 9
10 On a levelized cost basis over the proposed 10-year contract period, Enchanted Rock
11 estimates based on its own experience that Tier 2 diesel back up generation to cost roughly
12 $400/kW including all capital expenses and the net present value of operations &
13 maintenance (“O&M”) expenses. Tier 4 diesel back up generation costs roughly $600/kW.
14 The significant cost difference comes with an incremental improvement in local air emissions
15 (SOx, NOx, particulate matter, carbon monoxide, and volatile organic compounds).
6 1 A natural gas-burning reciprocating engine, for example, is significantly more
2 expensive at $850/kW due to its higher capital expenses, including gas interconnection costs.
3 It cannot compete with diesel economically, despite its ability to match or exceed all of the
4 performance characteristics of diesel back up generators (black start, transient response, ramp
5 time, power density, and fuel security) and its ability to reduce local emissions by 10-100x.8
6 However, by burning qualified renewable natural gas (“RNG”), such units, by comparison,
7 are estimated to have a net cost of $250-330/kW9. The low net cost provides a clear pathway
8 for an RNG-fired reciprocating engine to displace any diesel back up generation, utilizing
9 existing market price signals, i.e., BIP program payments. Furthermore, the RNG-fired
10 generation can be carbon-neutral or carbon-negative, depending on the RNG feedstock. The
11 conversion of diesel back up generation to an RNG-fired generator, in this case, serves the
12 dual purpose of providing much needed relief during times of peak energy use and reducing
13 air emissions in support of California’s clean air goals.
14 F. Regulatory Justification
15 1. Q. What is the regulatory justification for the proposal?
16 A. Back up generation has been an important component of Commission-
17 authorized interruptible tariffs and DR programs for decades. For example, PG&E had a
18 program in the early 1980s called the Auxiliary Power Supply program, which paid large
19 commercial/industrial customers to maintain their back up generation to reduce load during high
8 See Exhibit 5, Ryan Hledik et al., Decarbonized Resilience Assessing Alternatives to Diesel Backup Power, at 23 (Table 1), “Generator Emissions Factor Comparison.” The Brattle Group (June 2020). Brattle’s “Decarbonized Resilience” Whitepaper, https://brattlefiles.blob.core.windows.net/files/19026_decarbonized_resilience_white_paper_-_final.pdf. 9 The low estimate for market revenues includes the NPV of BIP payments at the current price. The high estimate includes a 3.5% escalator to approximate future potential increases in BIP compensation rates. The market revenues reported are net of the RNG fuel cost at $35/MMbtu for expected run-hours.
7 1 load conditions. Similarly, PG&E’s 1992 resource guide10 references “Customer Emergency
2 Generation Incentives” as a load management program. Thereafter, load management and DR
3 programs fell out of favor while the state experienced a decade of excess supplies. It wasn’t
4 until the energy crisis in the early 2000s that load management and DR programs re-emerged as
5 a top policy priority. Demand response remains first in the Loading Order of the State’s Energy
6 Action Plan.
7 2. Q. What is the origin of the fossil fuel back up generation prohibition?
8 A. The Commission instituted the fossil fuel back up generation prohibition
9 in Decision 16-09-056. The Commission found that “the Loading Order indicates that [DR] is a
10 reduction in demand that is not supported by fossil-fueled resources.”11 The Commission then
11 incorporated the prohibition into Resolution E-4906, which implemented the prohibition of
12 fossil-fueled back up generation being used to support DR beginning in 2019.
13 3. Q. Did the Commission allow for fossil fuel back up generation to use 14 alternative fuels?
15 A. The Commission attempted to do so. The Commission determined in
16 Resolution E-4906 that:
17 if a fuel (e.g., renewable gas, renewable diesel, biodiesel) has received renewable 18 certification from the California Air Resources Board, it is exempt from the 19 prohibited resource policy in D. 16-09-056.12
20 However, because CARB does not certify renewable fuels for stationary sources for back up
21 generation, the Commission’s attempt to allow back up generation to use alternative fuels has not
22 been successful.
10 Resource: An Encyclopedia of Energy Utility Terms, Second Edition, at 126 (Jan. 1, 1992). 11 D.16-09-056, at 20-21. 12 Resolution E.4906, at 78 (June 21, 2018).
8 1 4. Q. How does the Enchanted Rock proposal facilitate the transition of 2 fossil fuel back up generation to alternative fuels?
3 A. Enchanted Rock’s proposal acknowledges the value of back up generation
4 in providing DR capacity. The proposal incentivizes an orderly transition from fossil fuel back
5 up generation, typically diesel, to renewable-fueled, non-carbon emitting resources that can
6 improve the quality of back up generation when used and, more importantly, provide
7 meaningful, measurable, and predictable DR capacity.
8 5. Q. What additional benefits does the Enchanted Rock proposal provide?
9 A. By implementing Enchanted Rock’s proposal, the Commission would add
10 readily available resources that can perform during the highest net load conditions, even when
11 variable renewable resources are unavailable due to extreme weather conditions. In addition,
12 the Commission would support ongoing DR activities to maintain reliability even while
13 supporting California’s decarbonization efforts and complying with Governor Newsom’s July
14 30, 2021 Emergency Proclamation. Finally, the conversion of existing or planned diesel back
15 up generation with carbon-neutral RNG-fueled devices would result in a less polluting back up
16 generator when needed for emergency purposes when grid power is not available.
17 III. CONCLUSION AND VERIFICATION
18 1. Q. Does this conclude your testimony?
19 A. Yes.
20 2. Q. Was this material proposed by you or under your supervision?
21 A. Yes, it was.
22 3. Q. Insofar as this material is factual in nature, do you believe it to be 23 correct?
24 A. Yes, I do.
9 1 4. Q. Insofar as this material is in the nature of opinion or judgment, does it 2 represent your best judgment?
3 A. Yes, it does.
4 5. Q. Do you adopt this testimony as your sworn testimony in this 5 proceeding?
6 A. Yes, I do.
______/s/______Joel Yu Director of Regulatory and Legislative Affairs, Enchanted Rock
10 EXHIBIT 1
STATEMENT OF QUALIFICATIONS OF JOEL YU JOEL YU DIRECTOR OF REGULATORY & LEGISLATIVE AFFAIRS
[email protected] PROFESSIONAL PROFILE REDACTED Director of Regulatory & Legislative Affairs with 11 years of diverse energy sector, including 6 years of project & team management and policy & advocacy experience Houston, TX Proven Leader with strong presentation and interpersonal skills. 2019 Awardee of Linkedin.com/in/joel- Asian American Business Development Center’s Outstanding 50 Asian Americans in yu-b3591374/ Business Awards High-achieving, agile learner – Produced positive outcomes for internal and external clients on projects spanning a broad range of energy policy areas
SKILLS EXPERIENCE Negotiation DIRECTOR OF REGULATORY & LEGISLATIVE AFFAIRS Enchanted Rock, LLC, Houston | 2020 – Present Advocacy & Outreach Project Management As the Director of Regulatory & Legislative Affairs, I oversee the company’s portfolio of strategic energy policy priorities. My responsibilities include advising company executives on Energy Policy energy regulations and laws impacting commercial operations; representing the company in Federal Regulation key policy discussions with state and federal level decisionmakers; establishing processes and strategy for advocacy efforts; and building out necessary regulatory & legislative resources Communications through hiring, external consultant engagements, and trade associations. My achievements (Written and Verbal) include: Analysis & Research Established the company’s first legislative efforts at the Texas Capitol during the 87th Team Leadership Legislative Session post-Winter Storm Uri Successfully advocated for legislation that requires municipal utilities in Texas to allow Contracts customer-sited generation to access the wholesale market. Budgeting Developed national level awareness and recognition with state regulators and energy industry experts in the 2021 NARUC Summer Policy Summit General Session on microgrids EDUCATION PROJECT MANAGER, ENERGY POLICY & REGULATORY AFFAIRS MASTER’S DEGREE Consolidated Edison Company of NY, New York | 2017 – 2020 Business Administration Energy Policy & Regulatory Affairs is engaged on wholesale electric and gas market issues Specialization in that impact customers’ supply costs. As a Project Manager with the group, I managed multiple Finance, Management, regulatory projects at the NYISO, PJM, FERC, and NERC. I advocated on behalf of the and Economics company and its customers in committee meetings and before regulators, working with internal New York University stakeholders to develop and present policy positions and recommendations to company Dean’s List; Beta Sigma executives. I also engaged with external parties in coordinated advocacy efforts or in complex Gamma Honor Society multi-party negotiations. My achievements include: 2016 Leading the corporation’s internal task force on supply chain cybersecurity risks BACHELOR OF Successfully advocated for protection of sensitive bulk electric system information SCIENCE previously released in FERC penalty disclosures Chemical Engineering Successfully negotiated gas pipeline rate settlements in 2019, achieving over $10M Columbia University in savings for customers through 2022 2009 Performed quantitative and regulatory analysis in support of litigation and business development efforts GIAC Critical o Led internal effort to analyze and develop proposals for aligning wholesale Infrastructure markets (NYISO and ISO-NE) with public policy goals, including Protection decarbonization and renewable energy development Certification o Provided strategic regulatory insights for energy storage pilot programs 2020 Achieved effective reforms of interconnection process for new resources and technologies as chair of the stakeholder coalition representing the New York utilities JOEL YU DIRECTOR OF REGULATORY & LEGISLATIVE AFFAIRS
LEADERSHIP EXPERIENCE continued ACTIVITIES & o “Paving the Way for New Electric Resources: A New York Success Story,” AWARDS RTO Insider, October 30, 2017 by Joel Yu o Facilitated discussion and reached common understanding on the AWARDEE coordination of federal, utility, and state interconnection processes among Outstanding 50 Asian utilities, NYISO, and NY Department of Public Service staff Americans in Business Prepared and delivered effective presentations to educate and advocate internally Asian American and externally, including: Business Development o Annual company-wide strategic issues seminars Center o Regular briefings for the CEO and the senior executive team 2019 o External conference and trade association (EEI/AGA) presentations o Biweekly internal publication reporting on energy policy and regulatory issues DIRECTOR Harvest Fellowship Trained, mentored, and provided supervision for department’s Project Specialists 2018-Present engaged in PJM advocacy Managed department’s budget and participated in annual corporate budgeting Direct leadership process team in development of a new ministry Served as company’s municipal liaison to the town of Greenburgh, NY during storm geared to serve the emergencies Sleepy Hollow area PROJECT SPECIALIST, ENERGY POLICY & REGULATORY AFFAIRS DEACON Consolidated Edison Company of NY, New York | 2014 –2017 Korean Church of Westchester As a Project Specialist, I managed multiple regulatory projects at PJM and FERC, including 2010-Present capacity and energy market reforms and transmission cost allocation issues. I represented the interests of an affiliate company based on New Jersey, coordinating closely with consumer Mentor high school advocates and state commissions across the PJM states. and college students Provided quantitative and regulatory analysis to guide litigation team in PJM transmission cost allocation disputes, resulting in the cost avoidance of several $100M VOLUNTEER in annual transmission costs Sleepy Hollow Chaired the PJM Load Coalition which included representatives from state Community commissions, consumer advocates, public power entities, large industrials, and Development Program environmental interest groups 2010-Present Utilized trade press to advocate for consumer protections in wholesale energy Teaching Saturday markets Math and English o “FERC’s Artful Balance: Price Formation and Consumer Protection That programs for Works,” RTO Insider, April 11, 2016 by Joel Yu and Christopher Hargett economically o “Electric Market Offer Caps are a Vital Consumer Protection,” RTO Insider, disadvantaged September 28, 2015 by Joel Yu, Christopher Hargett, and Diana Barsotti students grade 2-6
OPERATING SUPERVISOR, ELECTRIC OPERATIONS Consolidated Edison Company of NY, New York | 2012 –2014 MENTOR Con Edison Corporate As a supervisor in Electric Operations, I supervised Local 1-2 utility workers and mechanics Mentoring Programs performing construction, operations, maintenance, and emergency work on underground 2017-2020 electric distribution equipment on Brooklyn and Queens network systems. I managed my crews to ensure we completed work while maintaining an accident-free record and in full compliance Supporting with corporate standards and all relevant federal, state, and local requirements. My development of new management experience includes front-line restoration efforts post-Superstorm Sandy and post-Hurricane Irene. employees and potential young talent from local colleges MANAGEMENT ASSOCIATE Consolidated Edison Company of NY, New York | 2010 –2011 EXHIBIT 2
EXCERPT OF HIDDEN GRID: MORE THAN EIGHT GIGAWATTS OF FOSSIL FUELED BACK-UP GENERATORS LOCATED IN JUST FIVE CALIFORNIA DISTRICTS
Hidden Grid: More Than Eight Gigawatts of Fossil Fueled Back-Up Generators Located in Just Five California Districts
May 2020 Steven Moss and Andrew Bilich 415.643.9578; [email protected]; mcubed-econ.org
variables, like engine size, temperature, load operation, fuel content, and control devices were excluded. With those caveats in mind, the 874 GWh of electricity could represent an estimated 562,000 metric tons (MT) of CO2/year. Diesel fuel generators made up approximately 89 percent of all units and accounted for 95 percent of estimated capacity in the five districts (Table 3). South Coast accounts for nearly 50 percent of back up and emergency generators included in the aggregated datasets, followed by BAAQMD, with 27 percent, and SJVAPCD, with 21 percent. (Table 4). Table 3: Back-Up Generators by Fuel Type
Fuel Type Number of Total Capacity Total Permitted Total Estimated Units (MW) MWh Permitted CO2 (MT) Diesel 21,659 7,946.91 632,133.26 442,248.20 Gasoline 102 14.19 2,629.23 1,727.48 LPG 562 47.63 4,555.34 1,770.85 Natural Gas 1,633 255.62 119,957.79 56,338.61 Natural Gas / 278 42.59 8,158.88 3,831.85 LPG Oil 90 19.35 3,482.03 2,328.04 Other 79 25.02 103,738.46 53,643.74 Total 24,403 8,351.32 874,654.98 561,888.76
Table 4: Back-up Generators by Air District
Number Total Capacity Total Permitted Total Estimated District of Units (MW) Operation (MWh) Permitted CO2 (MT) BAAQMD 6,496 3,810.45 240,530.27 129,700.08
EKCAPCD 15 6.44 0.006 0.00* SCAQMD 12,104 2,697.13 539,426.69 368,227.37 SJVAPCD 5,106 1,528.14 86,363.70 58,131.29 VCAPCD 682 309.15 8,334.33 5,830.03 Total 24,403 8,351.32 874,654.98 561,888.76
Limitations This analysis has a number of limitations, including: • Missing Air Districts – With only five of 35 air districts the analysis does not reflect a statewide picture for back-up generation capacity, particularly with significant population centers missing. • Varying Level of Detail Across Datasets – While most districts included the same general parameters (Table 1) there was substantial variation in details provided, particularly for fuel type and permitted use.
6 The values for permitted MWh/MT for Kern County are 0 because of missing data
6
EXHIBIT 3
OVERVIEW: BAY AREA BACKUP DIESEL GENERATION Diesel Backup Generation in the Bay Area
CEC Workshop on Research into Clean Energy Alternatives to Diesel Backup Generator Systems January 21, 2021
Jakub Zielkiewicz Advanced Projects Advisor [email protected] Bay Area Air Quality Management District Overview: Bay Area Backup Diesel Generation
• ~10,000 total permitted diesel engines throughout Bay Area • Data Centers • ~60 facilities identified with ~1GW diesel generator capacity • At least 15 proposed facilities with >1.5GW capacity • Diesel engines operating more than previously understood
CEC Workshop on Research into Clean Energy Alternatives to Diesel Backup Generator Systems Bay Area Air Quality Management District 3 January 21, 2021 EXHIBIT 4
CEC – ALPHABETICAL POWER PLANT LISTING 8/31/2021 Alphabetical Power Plant Listing
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AES Placerita Power Plant Licensing Alamitos Energy Center Alliance Century Energy Facility Public Participation in Siting Cases Alliance Drews Energy Facility Almond 2 Power Plant Strategic Transmission Planning Belridge Cogeneration Project and Corridor Designation Blythe Energy Project Synopsis of the Power Plant Blythe Solar Power Project Siting Process Border Project Bottle Rock Geothermal Power Plant Title 20 for Power Plant Siting CA3 Backup Generating Facility Certification Calistoga Geothermal Project - Unit 19 Campbell Power Plant Canyon Power Plant
Carlsbad Energy Center FILTER POWER PLANT Carson-Ice (SMUD) LIST Chevron El Segundo Chevron Richmond Replacement Colusa Generating Station Filter by Type https://www.energy.ca.gov/programs-and-topics/topics/power-plants/alphabetical-power-plant-listing 1/4 8/31/2021 Alphabetical Power Plant Listing Coso Navy 2 / China Lake Joint Venture Filter by Project Status Crockett Cogeneration Project Delta Energy Center Donald Von Raesfeld Project Filter by Technology El Centro Generating Station Unit 2 El Centro Generating Station Unit 3 APPLY RESET El Segundo Energy Center Elk Hills Power Project Enterprise Emergency Peaker Project Gateway Generating Station Genesis Solar Energy Project Gilroy Backup Generating Facility Gilroy Cogeneration Gilroy Energy Center Grant Geothermal - Unit 20 Great Oaks South Generating Facility Greenleaf 1 Temporary Power Generators GWF Tracy Combined-Cycle Power Plant Hanford Peaker Plant Henrietta Peaker Project High Desert Power Plant Humboldt Bay Generating Station Huntington Beach Energy Project Huntington Beach Generating Station Retool Project Ivanpah Solar Energy Generating Kern River Cogeneration Facility King City Cogeneration Project King City Energy Center La Paloma Generating Plant Lafayette Backup Generating Facility Lake View Geothermal Project - Unit 17 Laurelwood Data Center Lodi Energy Center Los Esteros Critical Energy Facility Los Medanos Energy Center Magnolia Power Project Malaga Power Plant Malburg Generating Station Mariposa Energy Project Marsh Landing Generating Station McLaren Backup Generating Facility Metcalf Energy Center MID Ripon Simple Cycle MID Woodland Generating Station 2 Midway Peaking Project Midway Sunset Cogeneration Mission College Data Center Mission Energy Champlin Mojave Cogeneration Mojave Solar Project (Abengoa) Moss Landing Power Plant Mountainview Generating Station NCPA Geothermal Plant No. 1 (Formerly NCPA 2) NCPA Geothermal Plant No. 2 (Formerly NCPA 3) Niland Gas Turbine Plant
https://www.energy.ca.gov/programs-and-topics/topics/power-plants/alphabetical-power-plant-listing 2/4 8/31/2021 Alphabetical Power Plant Listing Orange Grove Energy Center Otay Mesa Energy Center Palomar Energy Project Panoche Energy Center Pastoria Energy Facility Pio Pico Energy Center Procter and Gamble Power Plant Quicksilver Geothermal Project - Unit 16 Redding Peaking Riverside Energy 1 and 2 Riverside Energy 3 and 4 Roseville Energy Park Roseville State Power Augmentation Power Site Russell City Energy Center San Jose Data Center Santa Clara SC-1 Data Center SEGS III – VII - Kramer Junction SEGS IX-X - Harper Dry Lake SEGS VIII - Harper Lake Sentinel Energy Center Sequoia Data Center Shell Martinez Refinery Project SMUD Cogeneration Pipeline Project SMUD Cosumnes Power Plant Socrates Geothermal Project - Unit 18 Sonoma Geothermal Project - Unit 3 Stanton Energy Reliability Center Sunrise Energy Center Sutter Energy Center Sycamore Cogeneration Facility Texaco Wilmington Tosco Martinez Valero Cogeneration Project Walnut Creek Energy Park Walnut Energy Center Walsh Data Center Watson Cogeneration Project Wildflower Indigo Energy Facility Wildflower Larkspur Energy Facility
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EXCERPT OF DECARBONIZED RESILIENCE ASSESSING ALTERNATIVES TO DIESEL BACKUP POWER Decarbonized Resilience Assessing Alternatives to Diesel Backup Power
PREPARED FOR
Enchanted Rock, LLC
PREPARED BY Ryan Hledik Peter Fox-Penner Roger Lueken Tony Lee Jesse Cohen
June 2020
brattle.com | 0
Table 1: Generator Emissions Factor Comparison
Enchanted Rock Natural Gas Tier 2 Diesel Tier 4 Diesel Source Source Generator (lb/MWe‐hr) (lb/MWe‐hr) (lb/MWe‐hr)
VOC 0.001 NRTL Test Data 1,2 0.42 NSPS IIII 5 14.11 NOx 0.004 NRTL Test Data 1,3 1.48 NSPS IIII 5 CO 1.09 NRTL Test Data 1,3 7.72 7.72 NSPS IIII 5 PM/PM10/PM2.5 0.003 NRTL Test Data 1,4 0.44 0.07 NSPS IIII 5
SO2 0.007 AP‐42 Table 3.2‐3 0.016 0.016 AP‐42 Table 3.4‐1 NRTL Test Data 1 CO2 1,395 1,555 1,555 AP‐42 Table 3.4‐1 Notes: Provided by Enchanted Rock. For Tier 2 diesel, VOC and NOx emissions limit applies to sum of both emissions sources. Sources: [1] Enchanted Rock ISO 8178 D1 weighted test cycle emissions results from a single engine at a Nationally Recognized Testing Laboratory (NRTL). Actual field test results may vary due to site conditions, installation, fuel specifications, test procedures and engine to engine variability. [2] VOC emissions found to be below the minimum detection level of the equipment. [3] NOX and CO emissions data are the near‐zero hour non‐deteriorated emission rates which are not guaranteed emissions for the purposes of air permitting. These rates are typical for lower run hours which will increase with catalyst age. [4] PM emissions not expected to change with catalyst age, although differences in fuel quality could impact actual emissions. [5] NSPS IIII emission limit for electric generator rated between 560 kW and 900 kW. AP‐42: Compilation of Air Emissions Factors (EPA) https://www3.epa.gov/ttn/chief/ap42/ch03/index.html NSPS IIII: New Source Performance Standards, Subpart IIII: https://www.ecfr.gov/cgi‐bin/text‐ idx?rgn=div6&node=40%3A7.0.1.1.1.98
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