Testimony on Distributed Generation to the California Air Resources Board (CARB)
Comments of Bonnie Holmes-Gen,
Assistant V.P. For Government Relations
American Lung Association of California
Before The California Air Resources Board
November 15, 2001
RE: Proposed Regulation To Establish A Distributed Generation Certification Program and Guidance For The Permitting Of Electrical Generation Technologies
The American Lung Association of California, together with the California Thoracic Society strongly supports action by the California Air Resources Board (CARB) to adopt stringent statewide standards for small power generators called distributed generation or "DG." Small generators represent a growing sector of the energy market that has not been well controlled in the past and are responsible for significant air pollution emissions. It is extremely important that CARB establish stringent pollution control standards for small generator (DG) units to ensure that small power generators are as clean or cleaner than the leading technologies for centralized power plants, and to encourage the rapid development of clean, efficient and renewable power generation in California. We believe the proposed regulation before the CARB Board is a good starting point, and urge you to make the regulation even stronger to ensure that DG technologies meet CARB standards as soon as possible, and to reward the highest efficiency units.
As you are aware, there are now a wide variety of cleaner and renewable technologies becoming available for DG units including solar, wind and fuel cell technologies. Strong standards for DG will encourage continued investment in clean power sources that can be developed in locations close to the place where the energy is needed, while assisting California to achieve air quality standards and increased energy security.
We urge you to consider the following specific suggestions for strengthening the regulations before you today and developing additional regulations for small generators:
- Performance-Based Emission Standard
We join with the Natural Resources Defense Council in their recommendations for strengthening the Guidance and Certification Standards, and particularly emphasize the need for a single, aggressive, performance-based emissions standard for all DG units by 2003 to be included in the Guidance To Air Districts.
We urge the board to more directly recognize the greenhouse gas emission impacts and benefits of the regulations. DG standards should reward the highest efficiency technologies in order to reduce global warming emissions that contribute to poor air quality problems.
We urge the Board to pay particular attention to the need for strong enforcement programs to ensure that opportunities do not exist for circumventing the regulations. For example, CARB must ensure that portable generators and back-up generators not included in the regulations, especially diesel generators, do not circumvent the system and become used as DG. Another enforcement issue is the need to ensure that certified DG units only operate on the fuel that they were certified to use. For example, there could be a scenario where combustion turbines are switched to diesel or other distillate fuels such as "Jet-A" aircraft fuels in the case of a natural gas shortage.
We remain extremely concerned about the impact of toxic emissions from diesel back-up generators (BUGs) on air quality and public health. While we understand that the regulation before you today does not deal with BUGs used for emergency purposes, we believe the Board should move ahead rapidly to address emissions from the thousands of diesel BUGs throughout the state. We strongly encourage CARB to establish regulations to control pollution emissions from diesel emergency generators, and to ensure that no opportunities exist for non-emergency diesel generators to escape DG regulatory requirements.
In closing, the American Lung Association of California urges CARB to adopt the most stringent emission standards for small generators known as "DG." Pursuing clean and renewable sources for small power generators will help improve air quality and public health in California and promote the development and commercialization of zero and low-emitting power technologies.
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