April 27, 2020
The Honorable Susan Talamantes Eggman
State Capitol
Room 4117
Sacramento, CA 95814
Re: OPPOSE March 3, 2020 Eagle Crest amends to AB 2255
Dear Assemblymember Eggman:
We write to express our opposition to the March 3, 2020 proposed amends to your AB 2255 legislation (“Proposed Amended AB 2255”). As we have previously written, we oppose legislation directing the procurement by the California Independent System Operator (“CAISO”) of expensive long-duration bulk storage, such as the proposed Eagle Crest pumped energy storage project in the Eagle Mountains, surrounded by Joshua Tree National Park. This bill is unnecessary as the California Public Utilities Commission (“CPUC”) recently adopted an Integrated Resource Plan (“IRP”) Decision on this very issue and further the bill lacks urgency as it does not address any of the critical needs and challenges that we face as a result of the COVID-19 pandemic.
While advocates of the proposed Eagle Crest project frame the amendments as a study, it will unfortunately result in a multi-billion dollar ratepayer-funded bailout of the failing project. We respectfully ask you to not advance this effort.
The Proposed Amended AB 2255 props up one project, Eagle Crest. Using an arbitrary combination of sideboards, including cherry-picked modeling inputs, a project completion date of 2030, and the precedent-setting designation of the CAISO as a pumped-storage procurement entity, the bill stages the “study” to produce one outcome: the procurement of the Eagle Crest project. This mirrors the past two Eagle Crest Bailout bills which required the stacking of the deck in order to make the project pencil out.
The advocates of the Proposed Amended AB 2255 claim the bill is necessary because the CPUC neglects to include pumped storage in its planning. Yet just last month on March 26, 2020, after over a year of stakeholder engagement, the CPUC adopted an IRP Decision with considerable allocation toward long-duration storage (973 MW and 1,600 MW per two adopted scenarios), which includes pumped storage. While Eagle Crest advocated for the expeditious allocation of over 2,000 MW of pumped storage to prioritize its large 1,300 MW project over other long-duration technologies and projects that are more viable and economical, the CPUC has a mission to protect ratepayers from unnecessary projects and costs.
The recent IRP Decision makes it clear that Eagle Crest should continue to operate within this existing process rather than seeking a legislative workaround for the third year in a row.
While we are in a middle of a global pandemic that is causing severe unemployment and lost wages, we believe it is imprudent for the Legislature to undermine existing regulatory procedures that will ultimately lead to significant burdens to ratepayers.
Sincerely,
| Melissa Romero Legislative Affairs Manager California League of Conservation Voters | Neal Desai Senior Program Director, Pacific Region National Parks Conservation Association |
| Michael Madrigal President Native American Land Conservancy | Kathryn Phillips Executive Director Sierra Club California |
| Kate Hoit California Director The Vet Voice Foundation | Jay Ziegler Director, External Affairs & Policy The Nature Conservancy |
| Bill Allayaud Calif Director of Government Affairs Environmental Working Group | Kelly Catlett Associate Western States Director Hydropower Reform Coalition |
| Ronald Stork Senior Policy Staff Friends of the River | Kim Delfino California Program Director Defenders of Wildlife |
| Matthew Baker Policy Director Planning and Conservation League | Chris Shutes FERC Projects Director California Sportfishing Protection Alliance |
| Nick Jensen Conservation Biologist California Native Plant Society | Juan Altamirano Associate Director of Public Policy Audubon California |
| Kevin Emmerich Director Basin and Range Watch | Erica Martinez California Policy Advocate Earthjustice |
| Geary Hund Executive Director Mojave Desert Land Trust | Ileene Anderson Public Lands Deserts Director, Sr. Scientist Center for Biological Diversity |
| Edward L. LaRue, Jr., M.S.; Ecosystem Advisory Committee, Chairperson Desert Tortoise Council | Laura Cunningham California Director Western Watersheds Project |
| Steve Bardwell President Morongo Basin Conservation Association | Ryan Henson Senior Policy Director California Wilderness Coalition |
| Megan Brousseau Associate Director Inland Empire Waterkeeper | Phil Francis Chair, Executive Council Coalition to Protect America’s National Parks |
CC:
Assemblymember Laura Friedman
Chair, Natural Resources Committee