POSITION PAPER ON THE LOS ANGELES SOLAR ENERGY PLAN

The undersigned people/organizations represent an affiliation of leading environmental, social justice and health organizations who, collectively over the last 10 years, have successfully advocated for policies that have led to cleaner air, more renewable energy and measures to mitigate the impacts of climate change in Los Angeles and beyond.  As a group we represent numerous and diverse stakeholders, whose common goal is to promote clean energy in Los Angeles, with the larger goal of working to stem climate change.

Today the Los Angeles Department of Power generates approximately 75% of its energy from dirty fossil fuels like coal; meanwhile, our city has some of the dirtiest air in the country. Air pollution related health ailments kill more Angelenos each year than car accidents. To make matters worse, higher temperatures related to global warming can increase smog pollution, with the number of days conducive to smog formation projected to increase 75 to 85 percent in Los Angeles under just a moderate warming scenario.  By reducing air pollution while providing energy, solar power will help save lives. 

We are pleased with Mayor Villaraigosa’s commitment to promote clean energy for Los Angeles and for presenting an ambitious Solar Plan as part of the solution.  We have reviewed the mayor’s Solar Plan in depth and have reached consensus on some basic principles that are laid out in this document, as well as providing specific suggestions about how to strengthen the plan.  We view this plan as a starting point for discussion, an opportunity to engage multiple stakeholders throughout the scoping and implementation phases and look forward to discussing specific aspects with all involved.  As the Mayor, DWP and City Council move forward in developing the plan’s individual program components, we strongly urge you to take into account the following:

1.    We support the ambitious goals proposed by the Mayor’s Solar Plan.

• LA’s Solar Plan should aim to grow a robust and broad-based solar market, inclusive of large and small installations, of customer-owned and utility-owned systems.  It should integrate solar power into the daily operations of the city and its residents, and meet or exceed the goals of the state’s Million Solar Roof’s program.
• It is appropriate to take a multi-pronged approach to implementing solar, including customer-based programs, large-scale solar, installations on city facilities, and DWP owned and operated systems.
• Decentralized generation has an important role to play in the building of a safe, diverse generation portfolio. Programs with on-site generation potential such as the Residential and LADWP owned (in-basin portions) components should be robust.
• Solar hot water is an important technology to consider in the context of any solar plan.

2.    Develop the Solar Energy Plan in the context of the Integrated Resource Plan for DWP.

• The Solar Energy Plan should be viewed in the context of the larger effort of securing a diversified energy supply while moving away from fossil fueled electricity generation and not as a stand-alone issue.  As such, it should be incorporated into the city’s Integrated Resource Plan (IRP).  The 2007 IRP should be updated and a draft version circulated to engage all stakeholders for feedback.

3.    The Solar Plan should be designed to reduce barriers to clean power and ensure equitable and easy access for all.

• Ensure adequate marketing of the Solar Energy Plan so that all stakeholders that may participate are informed -which is particularly crucial for the success of a program such as SunShares- and so as to effectively reach as many potential participants as possible.
• Ensure access for lower income communities by addressing affordable housing and low-income communities’ issues individually and for each component of the plan (not applicable to Large Scale Solar).
• In order to facilitate access to solar and mitigate the high upfront cost barrier, a Municipal Property Tax Assessment financing model should be considered.
• Highlight SunShares as an opportunity for ratepayers unable to own or install solar to still support solar development.

4.    The Solar Plan should be developed to ensure that programs and applications are optimally designed and implemented.

• Bid requirements should reflect a concern for least-cost financing and encourage participation by the maximum number of market actors.
• Bid requirements should reflect a concern for least-cost financing and encourage the maximum participation of market actors. Requests for Proposals should not restrict the number of players by imposing onerous prerequisites.
• The Plan’s components should include performance control mechanisms to ensure solar installations are operated optimally (including a performance-based incentive for the Residential Program, such as a feed-in tariff option).
• Broaden the use of Net Metering, where applicable, as an incentive for optimal system installation and operation, as well as an incentive for energy conservation.

5.    The Solar Energy Plan must secure good jobs for Los Angeles
A robust and effective Solar Energy plan is a tremendous opportunity for green economic growth in the city. We would also like to suggest exploring funding opportunities with the US Department of Labor, which is offering support for workforce training initiatives.

• For components of the plan that do not specifically involve represented labor, the plan should include provisions for contracted work to ensure job quality, livable wages and the hiring of local and disadvantaged workers.
• In order to match needs and opportunities in the current local solar job market, as well as identify gaps, we encourage the city to engage stakeholder groups in coming up with a comprehensive workforce development strategy. This strategy would explore for example how to provide pathways for low-income, less-skilled job seekers, identify opportunities for them to acquire needed green skills and reach the entry-level positions.
• Training programs should be aligned with and linked to both educational institutions and actual employment opportunities
• Low-income census tracts should be given priority when considering where to site labor training programs. Training programs should be proactive in reaching out to workers from underserved communities.
• A requirement for certified workers also needs to be included
• Local manufacturers should be given a bidding preference

6.    In order to maximize the value of solar investments, the Solar Plan’s implementation should take place in the context of Energy Efficiency improvements

• The Solar Plan should be integrated with the City’s newly adopted Green Retrofit and Workforce Program.
• Where applicable, Solar Plan components should be integrated with DWP’s Energy Efficiency programs.
• In cases where the electricity generated is intended for on-site use, the city should consider giving preferential consideration to:
• Buildings that are 15% more energy efficient than the current Title 24 standards, for new construction,
• Buildings that fulfill the California Solar Initiative Energy Efficiency requirements, for existing buildings.

7.    Provisions must be made for transparency and accountability in the design and implementation of the Solar Plan

• It is important to include all stakeholders in the development of the Solar Plan (as well as the overall Integrated Resources Plan). Public workshops should be held to take input from as broad a group of stakeholders as possible.
• DWP should provide updates on the progress of the Solar Plan to the DWP Commission and City Council on an annual basis. These updates should include specific measures of progress data on actual-vs.-predicted performance, full financial accounting, data on time from project application to completion, tracking of job training and placement, and the identification of barriers and analysis on ways to overcome these barriers.

RECOMMENDATIONS ACCORDING TO SPECIFIC PROGRAM COMPONENTS

LADWP Owned

• We support the installation of solar systems on all City-owned and city “influenced” buildings (those where city dollars have been invested in building construction and/or renovation).  These installations are important as they represent the opportunity to strengthen public investments as well as providing clean, high wage jobs for local workers.  According to the Global Green Solar City Report (2005), Los Angeles has the potential for a minimum of 80MW of installed solar generation on city rooftops.
• Job training programs should be aligned with and linked to both educational institutions and actual employment opportunities, in the vein of the LAUSD and IBEW’s partnership in the East Los Angeles Skill Center.
• A share of job training programs should be sited in low-income census tracts and training programs should be proactive in reaching out to workers from underserved communities.
• In order to ensure maximum return for ratepayers, RFP’s for City-owned solar installations should prioritize system performance.

LADWP Large Scale Solar

• The program should be based on open Requests for Proposals. Bid requirements should reflect a concern for least-cost financing and encourage the maximum participation of market actors. Requests for Proposals should not restrict the number of players by imposing onerous prerequisites.
• When locating utility scale solar installations, the LADWP should use the environmental and cultural screens that have been applied in the Renewable Energy Transmission Initiative (RETI) process and should locate generating plants so that minimal new transmission is needed to deliver that power to the city’s grid.
• In order to ensure maximum return for ratepayers, RFP’s for City-owned solar installations should prioritize system performance.

Customer Solar Programs

The Million Solar Roofs Initiative requires municipal utilities to use a portion of their funding for customer solar programs.  DWP has approximately $313 million in State funds set aside for customer solar projects which should be used to fund the following programs:

Residential Program

• We urge the city to consider putting in place a performance-based incentive (such as a Feed-in Tariff or Rebate) to reach the target of 130 MW by 2020. Performance-based incentives ensure optimal design and operation of solar installations. Specifically, we would like to suggest allowing residential customers to have    a choice of either:
  -    A rebate per kWh, obtainable in conjunction with net metering, OR
  -    A feed-in tariff
  In order to avoid “double dipping”, DWP should ensure that customers who have already benefited from an LADWP rebate will refund part of the rebate as a prerequisite to enrolling in a feed-in tariff program.

• A Municipal Property Tax Assessment financing model should also be considered
• Net metering should be available to single-family housing as well as Virtual Net Metering to multi-family housing
• Ensure adequate marketing to maximize program participation
• Specific provisions should be put in place to ensure program access to low-income customers and affordable housing residents (multifamily rental, single family renter occupied, single family owner occupied). We would encourage the city to direct stimulus funds to provide grants to cover 100% of the cost of solar for affordable housing.
  -    Incentive program tailored (higher incentive) to low-income customers and affordable housing residents
  -    Allocate a set share of the program to affordable housing (expressed as a percentage of program cost, if rebate-based, with higher rebate that declines to its own MW capacity triggers or as a capacity-based target (MW) if feed-in incentivized)
  -    Include a 15 year minimum deed restriction
  -    LADWP should have dedicated staff to market and administer this affordable housing component, a clear marketing outreach plan and a user-friendly process that minimizes backlogs and clearly and accurately communicates the availability of funds.

Feed-in Tariff

• The tariff level, “market price plus green premium”, must allow for reasonable profit. A degression or progression schedule must also be included in the design: the tariff should be adjustable to market conditions and tied to program progress (increase in case of slow program progress, decrease if set too high)
• A provision should be included to encourage schools, non-profits, and affordable housing developers to participate in the program.

SunShares Program

• It is crucial the program be simple and well advertised
• The program should incentivize electricity conservation and lower consumption, through Virtual Net Metering and a fixed monthly fee should be based on electricity consumption
• A lower monthly fee should be available to low-income customers
• In order to ensure maximum return for ratepayers, solar installations for the purposes of the SunShares program should prioritize system performance.

Signed,

Colleen Callahan
American Lung Association in California
 
Bill Corcoran
Sierra Club
 
Bernadette Del Chiaro
Environment California
 
Erica Fick
Environmental Defense Fund
 
Mary Luevano
Global Green USA
 
Martin Schlageter
Coalition for Clean Air
 
Jim Stewart
Angeles Chapter Sierra Club

V. John White
Clean Power Campaign
 
Ryan Wiggins
EndOil/Communities for Clean Ports