Comments on "An Incentive Framework for Utility Procurement of Energy Resources"
Synapse prepared comments for use by TURN; a pre-workshop memorandum on the California PUC's proposal titled "An Incentive Framework for Utility Procurement of Energy Resources Modeled After Cap-and-Trade Principles of the Sky Trust," issued as Appendix B to the PUC's 4/6/04 Order Initiating Rulemaking (OIR). Synapse also considered the OIR itself, the ALJ's scheduling ruling of 11/23/2005, and the "Addendum to the Sky Trust Proposal: Alternative Approaches to Elements of the Policy Framework" of 2/3/2005. Synapse considered the strengths and weaknesses of the Proposal at a conceptual level and a nuts-and-bolts level. The proposal set out one model for a cap-and-trade system for greenhouse gas (GHG) emissions and certain alternatives to that model. The proposed system was described as applying to the resource selection and management the state's electric IOUs, to the natural gas distribution companies, or both. The documents briefly alluded to additional financial incentives for IOUs that related various ways to the proposed cap-and-trade system. Synapse's comments primarily related to the proposed cap-and-trade system as applied to an electric IOU and the financial incentive issue. Project completed in February 2005.