CaliforniaGeo Speaks to State IEPR

California mapCaliforniaGeo recently issued comments on the California Draft 2013 Integrated Energy Policy Report (IEPR). The document acknowledges geothermal heat pumps (GHPs) in the state energy mix, but the association questions if the California Energy Commission (CEC) has fully complied with AB 2339. The legislation requires the CEC to evaluate and recommend policies and implementation strategies to overcome barriers to GHP and geothermal ground loop technologies.

The CEC convened a GHP-focused workshop as its first step to explore barriers to the technology’s expanded use across the state. The next step was formation of a working group to continue the agency’s evaluation and discovery process. However, CaliforniaGeo contends that GHPs were not adequately represented in the working group summary, omitting important issues, policies and strategies including (but not limited to):

  • Benefits of recognizing GHPs as a renewable technology;
  • The extent that GHPs help achieve stated greenhouse gas reduction and energy efficiency goals;
  • The ability of GHPs to create permanent peak and base load reductions;
  • The lack of recognition or GHP role under the state’s Renewable Portfolio Standard; and
  • The potential of utility owned ground loops.

CaliforniaGeo requests publication of a full Staff Report that includes all of the work product from the GHP workshop and the working group. They assert that given the benefits of GHPs, the CEC’s initial recommendations onerously place all the burden of increasing GHP deployment on industry. At issue is a requirement that contractors submit an Alternative Calculation Methodology application that requires tremendous multi-step, expensive and time consuming efforts.

CaliforniaGeo requests that the CEC “undertake an immediate effort to work with industry to co-fund and co-develop the necessary changes to the Building Energy Efficiency Standards that will ensure GHPs are treated fairly as a well-performing energy efficiency measure.” And given the negative impact of not including GHPs in the state’s Building Energy Efficiency Standards, the association requests a “suspension of the T-24 compliance requirement on residential and non-residential projects utilizing geothermal heat pump systems.”