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rate laws, but this is a pretty low priority piece of legislation for the City of Eugene in my <br />opinion. <br />Contact Respondent Dept Updated Priority Policy Policy No Recommendation <br />Paul Klope PWE 01/11/2010 Pri 3 Support <br />Comments: I agree. <br />LC 123 <br />Relating Clause: Relating to renewable energy sources used to comply with a renewable portfolio <br />standard; creating new provisions; amending ORS 469A.020 and 469A.025; and <br />declaring an emergency. <br />Title: Allows facilities that generate electricity by using biomass or combusting <br />municipal solid waste to comply with renewable portfolio standard under certain <br />conditions. Specifies conditions under which State Department of Energy may <br />certify facilities as eligible for renewable energy certificates. Authorizes full <br />recovery of costs by public utilities in prudent energy investments related to <br />planning, financing, construction and operating by hydrogen power stations. <br />Declares emergency, effective on passage. <br />Contact Respondent Dept Updated Priority Policy Policy No Recommendation <br />Ethan Nelson PDD-BPS 01/13/2010 Pri 2 Oppose <br />Comments: Reasons: a. 5(a): By allowing generation from facilities in service prior to the 1995 date <br />in the RPS, disincentives new investments in renewable energy technologies and allows <br />generation from biomass facilities already calculated into ODOE's energy plans. <br />Oregonians get no net gain. b. 5(b): linked with 5a but further allows REC's to be banked <br />for use after 2026. Again, provides financial disincentive toward investments in new <br />clean renewable energy or conservation. c. 5(c): Okay section if this is decoupled from a <br />and b. But I am thinking there is an existing provision within the RPS legislation that <br />allows non-conforming generation units to be upgraded to meet the requirements (but not <br />sure). d. 6: Combustion of solid waste cannot be thrown into this without better research <br />and qualifications on what is being sent to the incinerator. This provision incentives <br />greater disposal and disincentives diversion and prevention opportunities. Also, existing <br />technologies such as the Marion County incinerator do nothing to add renewable capacity <br />to the system (again, already part of ODOE's energy plan calculations). e. Section 2: The <br />language is way too loose to support. What criteria will the PUC use in determining <br />"prudent investments"? This can move forward separate from the RPS provisions in this <br />LC. It is fine to request cost recovery through rates when investing in new technologies, <br />but that needs to be carefully evaluated and monitored, which is not how this bill is <br />written. f. Section 3 6(a-c): Read comments on d above. MSW incineration should <br />qualify as renewable energy, only if there are other concomitant steps taken to improve <br />the diversion and prevention of wastes. What is happening is a "garbage to gold" strategy <br />that does not address the carbon or natural resource impacts of waste generation in the <br />first place. A comprehensive waste bill that addresses lifecycle should move forward with <br />4 | Page <br /> <br />