Naperville Greenhouse Gas Calculations

Documentation provided by this webpage consists of an excerpt of written comments provided to the City of Naperville, Illinois, as part of a public proceeding conducted by the City of Naperville, Illinois (the City) in March 2013 held pursuant to Public Utility Regulatory Policies Act of 1978.  This type of public proceeding is commonly referred to as a “PURPA hearing.”  Comments pertain to the Naperville Smart Grid Initiative (NSGI).

In prior PURPA hearing comments, it was noted that the City had provided misleading information on carbon emissions in a “Smart Grid Fact Sheet” available at the following hyperlink for viewing:  NSGI Fact Sheet.  Specifically as stated in my comments, “Units of measurement are critical in these calculations, and if you are not clear on those units or over what time period the emissions occur, the figures are meaningless and misleading.”

From that document, the statement in question is:  “NSGI will reduce carbon emissions by 180,000 tons, the equivalent of taking more than 31,000 cars off the road for a year.”

I explained that the Naperville NSGI Grant Application, dated August 6, 2009, on page 37, makes the following statement:  “Reduced energy use as a result of customer demand response programs, as well as improved network efficiency, will result in the avoidance of over 180,000 tons of carbon over a 15-year period.”

I also found a newspaper article where the carbon emission estimates were characterized in a way consistent with the City’s Grant Application.  A Tribune article on October 30, 2009, has the following statement, “Alan Poole, … said … he expected the city would … reduce 180,000 tons of carbon emissions over the next 15 years.”

Thus, it is clear that the basis for the “180,000 tons number” is considered a cumulative forecast over a period of 15 years.  It is likely that the carbon emission’s estimate was made in this manner because the Naperville smart grid project was economically justified over a period of 15 years and also due to the fact that the carbon emission reductions are expected to grow over time, starting in the first year at a minimal level.  Each year’s emission savings is expected to be different from another, based upon an “expected” increase in participation in energy control programs by the public over time.  Thus, it is not proper to characterize the emission reductions by a single number on a year by year basis.  However, in several instances, that is exactly what the City of Naperville has done, either by inference or explicit statement.  In the process, the City has significantly exaggerated the societal benefits of the smart grid deployment.  Beyond the “Smart Grid Fact Sheet” already mentioned, I will present two even more blatant examples of vastly exaggerating the initial investment-related calculations.  Remember that the initial investment-related calculations for Naperville show that the carbon emission benefits would grow to a total of 180,000 tons over a 15 year period.

The City NSGI “Customer Relations/ External Communications Plan,” dated April 15, 2011, states that carbon emissions will be reduced by “180,000 tons annually, [emphasis added] the equivalent of taking more than 31,000 cars off the road each year [emphasis added].”  The exact wording and website document link are shown below.

Page 12 at the following link:

NSGI Communications Plan

Do you realize how significant of an error and exaggeration this isThe information being disseminated by the City is 15 times (or 1,500%) the calculated forecast!

Another example is contained in [a slide from] the “State of the City 2011, The Year in Review,” presentation, where the City clearly states that 180,000 tons is the “ANNUAL [emphasis added] carbon emission reduction due to NSGI.”

Slide 68 [from the presentation, with an arrow pointing to the exaggeration, is shown below:]

NSGI Benefits

At this point I haven’t even asked the obvious question of how the initial 180,000 number was calculated.  No true basis information is available from City documentation that I was able to discern on the exact formulation or origin of this number.  Because of this, and from a technical perspective, there is some uncertainty from my review as to whether the number actually represents 180,000 tons of “carbon” or 180,000 tons of “carbon dioxide.”  I have discovered instances where conflicting statements in City documentation would support both possible conclusions.  Depending on the resolution of that issue, there is a possible additional discrepancy of nearly 400% on the hypothesized societal benefit of the potential greenhouse gas emission reductions forecasted by the City for its AMI deployment.


As I have shown from previous correspondence, as we review each possible relevant topic, whether it be issues related to invasion of privacy, data security, RF emissions, consent issues for smart meter installations, opt-out fees, overall health impact, and now the accuracy and reliability of the societal benefit calculations, there are serious questions to be resolved before the City can consider itself in compliance or even meeting the spirit of what is expected by the Federal Energy Standards.

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