Stevenson, Garrett
Subject:FW: MSC 11/14 Public Comment - Agenda Item 2 - Support for 100% Carbon Free Electricity by 2030
-—Original Message-—
From; Mackenzie Ostrowski < >
Sent: Tuesday, November 14, 2023 10:24 AM
To: Sabha, Tamer <[email protected]>; Stevenson, Garrett <[email protected]> Cc: Williams, Felicia <[email protected]>; Jones, Justin <[email protected]>; Hampton, Tyron <[email protected]>; Lyon, Jason <[email protected]> Subject: MSC 11/14 Public Comment - Agenda Item 2 - Support for 100% Carbon Free Electricity by 2030 Dear City Council Members,
My name is Mackenzie Ostrowski, I am a resident of District 2, and I urge you to support a plan for 100%carbon-free electricity by 2030. Living in Los Angeles County all of my life has shown me the wide-scale support our communities have for climate change mitigation through carbon-free electricity. Achieving 100% carbon-free electricity is crucial for our future and we need your support to make this happen. By making real, equitable strides to achieve carbon-free electricity, we have the opportunity to be a guiding force for renewable energy use.
Thank you for your time,
Mackenzie Ostrowski
1 Stevenson, Garrett
Subject:FW: Agenda Item 2. Adoption and Approval of 2023 IRP From:
Sent: Tuesday, November 14, 2023 12:10 PM
To: Stevenson, Garrett <[email protected]>
Cc: Williams, Felicia <[email protected]>; Hampton, Tyron <[email protected]>; Jones, Justin <[email protected]>; Lyon, Jason <[email protected]> Subject: Agenda Item 2. Adoption and Approval of 2023 IRP TO: Municipal Services Committee
DATE: November 14, 2023
FROM: Genette Foster, Council District 2
RE: Agenda Item 2. Adoption and Approval of 2023 IRP
In the final slide for their presentation, PWP requests that City Council support the policy goal of 100% carbon-free by 2030 through utilization of the Waypoint framework supported by 2023 IRP Scenario 2 modeling results. Although PWP's Agenda Report dated December 4, 2023 devotes virtually half (3 out of 7 pages) to repetitive mentions of "Waypoint", neither the methodology nor its actual incorporation into the 2023 IRP are explained. There is vague reference to "Critical Path" but no attempt at critical path analysis aside from comments in Item 1-PWP2023 Supply Chain Issues regarding increased lead times for procurement and contracts.
PIVP Slide 8 is identical to IRP Figure 209 Implementation Timeline. This table lists many proposed actions but fails to connect tasks which constitute "Critical Path" to achieve the stated goal of carbon-free by 2023: Distributed Energy Resources, Local Battery Storage and Community Solar. The following table is based on Figure 209, presenting these key tasks according to PWP's stated timeline.
RE: Figure 209. 2023 IRP
Implementation Timeline
20242025202620272028
Distributed Energy Resources
(DERs)andEE
Study
Expansion
Identify
Potential
Projects
Review GoalsSeek Pilot
Programs
Local Battery StorageLocal ProjectsSeek
Additional
Sites
Complete
Additional
Projects
Community SolarEvaluate
Community
Solar
Identify
Potential
Projects
Implement
Community
Solar Program
PWP's leisurely implementation timeline does not reflect any urgency. In fact, it would likely result in PWP's failure to achieve significant goals by 2028 when nothing is scheduled. 1 Distributed Energy Resources (DERs) - Costs for Scenario 2 are inflated by false assumptions about rooftop solar which is paid for by private property owners. At the MSC Meeting October 10, a representative of Pasadena Unified School District stated that many PUSD roofs would be eligible for rooftop solar installation; this is not mentioned.
Study Expansion and Identify Potential Projects are two parts of the same task which should be carried out in 2024 so that PWP would be ready to Seek Pilot Programs by 2025.
Local Battery Storage - Slides for MSC Item 1 identify Transformer Shortage as an Overall Major Risk with potential impact on Battery Energy Storage ("BESS") project. Scenario 2 includes a total of 665 MW of battery storage. Only 105 MW of battery storage are currently available: 85 MW to be added in 2023 and 20 MW to be added in 2027. Consultants E3 note PWP's reliance on Energy Storage, especially in Scenario 2 (see E3 Slide page 50). PWP should quickly acquire a minimum of 100MW of battery storage. All scenarios require that substantial storage be in place by 2025. The current 25MW procurement initiative is inadequate. Increase storage over the next 4-5 years, piloting new storage technologies including Long Duration Storage with federal IRA funding.
Local Projects and Seek Additional Sites should both be completed in 2024 to account for supply chain issues that could affect additional projects and heavy reliance on energy storage to meet goats.
Community Solar - Slidel3 for MSC Item 1. Includes Government Incentives: "The availability and extent of government incentives, subsidies or tax credits can impact the overall cost of renewable energy contracts. In some cases, these incentives can offset high upfront costs." However, there is virtually no mention of participation in the Inflation Reduction Act which could reduce costs. The 2023 IRP does not mention any active applications for federal grant programs although PWP filed a Notice of Intent to apply for Greenhouse Gas Reduction Funds. Also unmentioned are eligible areas for Justice40 Disadvantaged Community (DAC) funds in portions of Council Districts 1, 3 and 5. • Evaluate Community Solar and Identify Potential Projects should be performed simultaneously in 2024 so that PWP is ready to implement a Community Solar Program in 2025.
PWP's ambivalence to meeting the goal of carbon-free electricity by 2030 as mandated by City Council Resolution 9977 is demonstrated in Appendix 28: [DRAFT] Renewable Portfolio Standard Procurement Plan. "Though the SB100 mandates require POUs to procure 60% of their retail needs through renewable power by 2030, PWP must strike a balance of meeting this need while being mindful of its cost, reliability and sustainability obligations and proprieties. Over or under procuring renewable energy in comparison to requirements come with risks and opportunities" (page 269 of 297).
Figure 4: PWPSB 100 Procurement Plan from 2023 IRP projects retail sales for Compliance Periods 4 (2021-24), 5 (2025- 27) and 6 (2028-30). Projected Retail Sales for CP-4 are based on actual sales. With no explanation, the projected load forecast for CP-5 increases dramatically with an average annual increase of 18.3% for the three years between 2024 and 2027. The projected load forecast for CP-6 then drops to an average annual increase of only 1.5%, virtually flat for the three years between 2027 and 2030, again with no explanation.
RE: Figure 4-SB 100
Procurement Plan+
Compliance Period 4
(2021-2024)
Compliance Period 5
(2025-2027)
Compliance Period 6
(2028 - 2030)
Projected Retail Sales
(MWh)
Average annual
increase from previous
compliance period
2,064,1293,417,985
18.3%
3,579,142
1.5%
2 Pasadena Water and Power's draft 2023 IRP does not put forth a firm commitment to achieving the City's goal of Resolution 9977: 100% Carbon-free by 2030. City Council must reaffirm its commitment to Resolution 9977 by demanding additional adjustments to the draft 2023 1RP.
City Council consideration of Attachments 28 and 29, Renewable Portfolio Standard Procurement Plan and Enforcement Plan is premature.
PLEASE VOTE NO for any motion to approve the Renewable Portfolio Standard Procurement Plan and Enforcement Plan.
3