Thoughts on Solar

Last month we wrote about a rebate program being offered by Pasadena Water & Power for both the purchase of an Electric Vehicle (new or used) as well as the installation of EV chargers.  Which got us to thinking, don’t the other local utilities have something similar?  Well guess what, they do!  Read on to see what might be available from a utility near you!

Southern California Edison (SCE)

SCE offers rebates for both purchasing an EV as well as installing a level 2 (i.e., 240 VAC) charger.

EV Rebate

The SCE rebate for purchasing an EV is $450.  Here are the requirements:

• You must be an SCE residential customer (vehicles registered to businesses are not eligible).
• The EV must be among the vehicles listed on the Drive Clean website (which lists 35 models of EVs from 2018 alone!).
• The vehicle’s registration address must be the same as the customer’s address with SCE, but the name on the service account need not be the same as that of the vehicle owner.
• The vehicle’s registration is current with the State of California.
• The vehicle has not received more than two rebates in the past.
• If you have multiple EVs, each vehicle is subject to a rebate if the above qualifications are satisfied.

To apply for the SCE EV rebate, go here.

Charger Rebate

SCE also offers a rebate of $500 to install a Level 2 charger at your home.  Here are the requirements:

• You must enroll in one of the available Time-of-Use (TOU) rates.  BE CAREFUL!  Depending on your usage patterns this might be a very expensive option!  Run on Sun can, for a nominal fee, assess your present usage and let you know what your annual bill would do under each of the available TOU rate options.  Please contact us if you are interested in our providing you with this service.
• You need to pull a permit for the installation, and have the work performed by a C-10 electrician (B contractors are not allowed to participate in this rebate program).
• You need to provide a copy of the signed-off permit after inspection and a copy of your permit receipt (be sure the electrician provides you with these documents).

To apply for the SCE EV charger rebate, go here.

Los Angeles Department of Water & Power (LADWP)

LADWP does not appear to offer a rebate for the purchase of a new EV, but they do offer a rebate for purchasing a used EV, as well as installing an EV charger.  Their overall EV page is here.

Used EV Rebate

LADWP is offering a pilot program for the first 2,000 approved applicants who purchase an EV two or more years old (i.e., model year 2016 or older).  The rebate is $450 and opened on April 1, 2018. 

Here are the requirements:

• EV must be two years old or older, and never received an LADWP rebate for its purchase previously.
• EV must have been purchased after April 1, 2018.
• Permanent residence must be served by LADWP
• Complete the rebate application - download it here.
• Copy of DMV registration
• Copy of bill of sale
• Proof of residence

EV Charger Rebate

LADWP offers a $500 rebate for installing a Level 2 EV charger (i.e., 240 VAC).  Program requirements are:

• Completed rebate application - download it here.
• Proof of EV charger purchase - paid invoice that includes
• Purchase date
• Retailer name, address and phone
• EV charger make and model
• How paid for - check, credit card, etc.
• DMV registration that shows EV registered at account address
• Photos of completed installation, nameplate of charger (showing serial number, make and model number)

Interestingly, LADWP does not specifically require the installation to be permitted and inspected.

Burbank Water & Power (BWP)

BWP offers a rebate of $500 for residential EV charger installations.  (You can access the rebate application here.)  They do not appear to offer a rebate for purchasing EVs.

Program requirements for the EV charger rebate are:

• Applicant must be a BWP customer or charge their EV at a location served by BWP.
• Agree to be switched to a Time-of-Use rate in return for the EV charger rebate.  CAUTION: this could be an expensive switch.  Be sure to consider how and when you use energy before agreeing to switch.
• Application must be submitted within four months of purchase.
• Installation must be hardwired (i.e., not plug-in) Level 2, and permitted and inspected by the City.
• Supporting documentation including:
• Copy of charger purchase receipt/invoice
• Copy of installation receipt
• Copy of signed-off permit
• Copy of DMV registration
• Photo of installed charger

Glendale Water & Power (GWP)

As is often the case, GWP’s programs mirror those of BWP.   GWP offers a $500 rebate for residential EV charger installations, but nothing toward the purchase of the EV itself.  Here’s a link to their overall EV page.  One interesting wrinkle, GWP issues the rebate in the form of a credit on your GWP bill - none of the other rebate programs said that.

Here are the requirements for the EV charger rebate:

• Applicant must be an active GWP account holder.
• Charger must be a new, Level 2 (i.e., 240 VAC) charger, and the application must be submitted within four months of purchase..
• Installation must be permitted and inspected by the City if the charger is hard-wired.
• Supporting documentation includes:
• Copy of charger receipt/invoice
• Photo of installed charger
• Copy of labor receipt (optional)
• Copy of the signed-off permit (if required)
• Copy of DMV registration and car purchase or lease agreement

Access the GWP EV charger rebate application form here.

Run on Sun is proud to call Pasadena home.  We absolutely love this place.  But it isn’t perfect, as evinced by the latest report on where Pasadena gets its power - that’s right, the 2016 Power Supply Content Label is now out, and it is a mixed bag to say the least!  Here’s our take…

Every year, California utilities are required to post a table that reflects the sources of the power that they provide, the “Power Supply Content Label."  We wrote about PWP’s energy mix when the previous label was published, and at the time we noted that coal constituted 34% of the energy supplied, with natural gas another 6% - a full 40% coming from fossil fuels.  Surely a year later the news would be better, right?

Not so much - here it is, read it and weep:

2016 Power Supply Content Label

Both coal and natural gas went up!  While the overall statewide mix is just 4% coal, PWP gets 10 times that much, a whopping 40%!  Combined with natural gas and 52% of our power comes from fossil fuels.  Moreover, half of the “renewables” comes from burning biomass and waste, thereby also contributing to greenhouse gas emissions!  (One bright spot - utility scale solar now accounts for 5% of all energy, up from zero the year before.)

Lest you think all of the small munis are as bad, not so.  Glendale Water and Power, in particular, is kicking PWP’s backside, with only 5% from coal, and just 29% from natural gas.  GWP also gets 26% of its power from wind!  (Here’s a link to their power label.)

PWP is making some strides, however.  Last year they replaced a 51-year-old steam plant with a combined cycle turbine unit that can produce power within minutes, compared to the 72-hour start time for the old system.  But at 52% fossil fuels, PWP still has a long way to go!

We wrote last month about how Glendale was late getting to its required Feed-in Tariff program and that the design that they were advancing was seriously flawed. Well the window on the FiT has finally opened and guess what - it is worse than we thought!

When we first looked at the details of GWP’s FiT we were concerned that there had been no public input into the program’s design.  Moreover, the amounts that were going to be offered - based on the staff’s report to the City Council - revealed energy prices so low that no intelligent developer would go anywhere near the program.

The published proposed price for FiT energy - 9.292¢/kWh for peak time delivery and 7.251¢/kWh for off-peak - were well below what a program needed to be subscribed.  In fact, those prices were very close to what was being offered in Anaheim and Riverside - two program which had not seen a single FiT application in two years!

Well as bad as we thought all of that to be, we just learned that the reality is far worse.  GWP just kicked off their FiT website (which curiously has the title: Revenue for Demand Response) which includes a link to the current Offer Price.  As of July 1 (though really not available until today) here is GWP’s actual offer price for FiT energy:

These new prices are 15% lower for peak deliveries and 10% lower for off-peak from the prices described to the City Council just last month! (Interestingly, their fees have not reflected a similar price reduction.)  We previously calculated the FiT payment in Year 1 for a 100 kW project to be $13,599 based on the allocation of energy by peak versus off-peak times.  Under the new rate structure that payment in Year 1 declines to just $11,688, a 14% hit.

The website is typically devoid of any data explaining how the new price was calculated, but does it really stand to reason that GWP’s “avoided costs” for energy declined by 15% in the past month for peak time deliveries?  While the materials submitted to the City Council contained a sample calculation showing how staff reached the originally proposed values, no such calculation is visible on the GWP website.  Were the numbers used last month simply fictitious? Or has there been some amazing change in fortunes for GWP’s ability to purchase energy - mind you this at a time when energy prices throughout Southern California are spiking up 59% due to the loss of the San Onofre Nuclear Generating Station.  Amazing.

Looks like I won’t have to be making good on my bet come September.  Pity.

As expected, the Glendale City Council yesterday voted to approve a Feed-in Tariff program patterned after programs that have failed.  Here’s our final report, for now.

One clear tell that the FiT proposed by GWP was a non-issue: no other solar company bothered to comment on it before the City Council.  As for the City Council itself, another tell - two of the five Councilmembers were participating via Skype and phone - but they both bailed after voting on the City’s budget but before the FiT came up for a vote.

Which left only me.

For the second week in a row, I was the only speaker to address the FiT.  I pointed out to the Council the failure of the programs in Anaheim and Riverside - the models for the GWP program - to yield a single solar installation in more than two years.  I reminded them of what we were told by the woman in Anaheim - that there is a difference between designing a program to meet the letter of the law and designing a program that works.  I acknowledged that they were going to pass the ordinance, because they had been told that they had no choice - they were stuck with buying a pig in a poke.  I encouraged them to revisit the issue in three months.  If GWP was correct, and their program was destined for greatness, we would certainly know by then - but if I was right, perhaps it would be proper to revisit this program and try to design one that would actually work.

That argument received some traction with the Council - and I have already set the reminder for three months from now to revisit this with the Council.  (Ironically, if you are speaking about something that is not on the agenda, they give you 5 minutes to speak, but for actual business before the Council, they only give you two. So when I return in September I will actually be able to layout my case in some detail!)

Once again, Councilmember Ontero picked up on what I said and asked Staff whether they had, indeed, designed a program that could only meet the letter of the law but not actually accomplish anything.  And again, GWP’s Chief Assistant General Manager, Steve Lins responded but did not actually answer the question.  Instead he brought up LADWP’s Ratepayer Advocate as complaining that LADWP was overpaying (an old argument that was rejected twice - by the LADWP Board and by the LA City Council).

Beyond that, Mr. Lins insisted that my complaints were that “my project” didn’t pencil out and that was why I was complaining.  Of course Mr. Lins knows nothing about my motivations so his speculation was unjustified.  For the record (since Council rules did not afford me an opportunity to respond), Run on Sun did not have a client that we were representing here - we were simply advocating for sound public policy in support of solar.

So the program is now adopted and we will wait and see how this plays out.

We attended Tuesday night’s Glendale City Council meeting to share our thoughts with Councilmembers regarding GWP’s proposed Feed-in Tariff.  As might be expected, it was not an encouraging experience - here’s our report.

In our previous post analyzing the proposed FiT, we noted that essentially small players could not produce projects that would pencil out and only the very largest projects - 1.4 MW under the proposed guideline - would be economically viable.  Given the limited size of the overall program - just 4.2MW - three of those largest possible projects would completely subscribe the program.

At the outset of discussion on this item, Glendale Mayor Dave Weaver commented that this was one of the most complicated staff reports he had ever seen and he implored staff to make their presentation something that lay people could understand.  You can watch the full discussion in the clip below - my comments begin around the 11:00 mark.

However we heard something new during the staff presentation - by Senior Assistant City Attorney Christine Godinez - that surprised us: the contracts being offered under the FiT would not be for a set price for the duration of the contract, nor were they even contracts with an established initial rate that would be subject to an escalation provision going forward.  Instead, we were told that the price would be adjusted every quarter with the new price applied to existing contracts!

We decided to follow-up on that point and spoke today with Ms. Godinez.  She confirmed that payments under 20-year FiT contracts would change every quarter and cited the programs in Anaheim and Riverside (but not LA) as examples of that approach.  Frankly, we do not see how any developer would agree to such an approach when, as Ms. Godinez conceded, the price to be paid could go up or down with no way to predict what it would do in advance.  Think about it, what developer is going to spend hundreds of thousands of dollar to sell renewable energy based on a reimbursement rate that is solely and unilaterally under the discretion of the buyer?  Indeed, does this even meet the definition of a long-term contract when the most important term - price - is undefined?

That got us to wondering what was really going on in Anaheim and Riverside and whether those programs had been successful.  We were able to confirm that both cities have FiT programs that change their rates annually (as opposed to quarterly under GWP’s proposal) but we could not see any evidence of actual FiT installations in either City.  We managed to speak to representatives of both utilities.

Ms. Carrie Thompson, an Integrated Resource Planner for Anaheim, explained that they do adjust their offered price each year but, contrary to what GWP is proposing, that price is then held fixed for the lifetime of the contract.  (The price is presently 4.587¢/kWh - which is roughly where it has been since the program began in 2011.  It is due to increase by 8/10’s of a cent on July 1 - but please, curb your enthusiasm.)  But this is largely a theoretical difference since not a single project application has been submitted to the City since the program went live more than two years ago.  Ms. Thompson, who was extremely helpful - calling us back twice to return our call - noted somewhat wistfully that there is a difference between “designing a program that meets the letter of the law and designing a program that works.”

“Jerry” from Riverside told us that their FiT price of 5.8¢/kWh is the same price they have offered since the program went live in 2011 and that it was tied to the City’s  price for energy under long-term utility-scale renewable energy contracts with remote suppliers.  He said that the City understood that at that price, there would be no developers building projects under the FiT because “it cannot make economical sense."  Indeed, the City, “doesn’t want solar here” and in that sense their FiT “program” has been a success - there are no FiT projects in Riverside.

In other words, GWP is patterning its FiT program on two programs that were designed to fail and which have resulted in the installation of no solar whatsoever within their respective City boundaries!

Two other points - Councilmember Quintero (at 14:18 into the video) pointed out his concern that entrepreneurial individuals who might want to install solar along San Fernando road would be shut out of this program because the rate was too low.  Of course, he is exactly correct - no commercial building owner is going to be able to participate in this program because of the low rate being paid and the tremendous lack of clarity about where payment rates will go in the future.

The second point concerns the comments from GWP’s Chief Assistant General Manager, Steve Lins.  He sought to contradict my statement that there was no net-metered rebate program for commercial customers in Glendale.  No, he said, there was a program - its just that it was over-subscribed last year (i.e., it ran out of funds without notice) and that there would be no funds for it this year because it has been over-subscribed in the past - “a victim of its own success."  Of course, that is not a rebuttal of my assertion that no such program is presently available in Glendale.

In response to Councilmember Quintero’s concern, he responded that under the statute (SB 1332) they could only pay based on their avoided costs.  But that, of course, is a misreading of the statute which makes avoided costs only one component to be considered.  Here is the relevant text of the law:

The governing board of the local publicly owned electric utility shall ensure that the tariff adopted pursuant to subdivision © reflects the value of every kilowatthour of electricity generated on a time-of-delivery basis, and shall consider avoided costs for distribution and transmission system upgrades, whether the facility generates electricity in a manner that offsets peak demand on the distribution circuit, and all current and anticipated environmental and greenhouse gases reduction compliance costs. The governing board may adjust this value based on the other attributes of renewable generation. The governing board shall ensure, with respect to rates and charges, that ratepayers that do not receive service pursuant to the tariff are indifferent to whether a ratepayer with an electric generation facility receives service pursuant to the tariff.

SB 1332 - Public Utilities Code §399.32(d)

Moreover, because GWP released no information - nor held any public hearings - about how it calculated avoided costs, even that assertion is subject to question.  Given that the stated purpose of SB 1332 is to “encourage electrical generation from eligible renewable energy resources… located within the service territory of, and developed to sell electricity to, a local publicly  owned electric utility,” comparing avoided costs from large, utility-scale resources located far away is not an appropriate comparison.

Bottom line: GWP is proposing, and next week the Glendale City Council is almost certain to approve, a program that ignores the intent of the law and may well be in violation of it.  One thing is for certain, very little, if any, renewable energy will be generated as a result of this program.  And apparently - like in Riverside - that is the whole point.