Sabha, Tamer
From:
Sent:
To:
Subject:
Blair Miller-
Tuesday, December 5, 2023 12:53 PM
Kenebrew, Jerice; Stevenson, Garrett; Sabha, Tamer; Lyon, Jason; Jones, Justin; Williams, Felicia; h^ampton, Tyron
MSC 12/5 Public Comment - Agenda Item 1 - Support for 100% Carbon Free Electricity by 2030
CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button. Learn more....
City Council Members,
I urge you to require that the Integrated Resource Plan be updated to achieve 100% carbon free electricity by 2030.
Specifically, I call your attention to two points from the Pasadena 100 analysis of the latest draft of the IRP:
1) The Draft IRP is back loaded so that the Waypoint in 2028 will be too late to make necessary adjustments.
Please direct staff to update the plan for distributing resource procurement, including a 2026 Waypoint for evaluation of all aspects of the plan.
2) The Draft IRP minimizes resources from residential and community solar, and threatens the only incentive for private investment in local generation.
Please direct staff to remove changes to net energy metering that risk destabilizing the market, and to begin a marketing campaign for private investment in rooftop solar.
Pasadena 100 is doing a tremendous amount of work to help Pasadena actually achieve the stated goal of 100% carbon free electricity by 2030. Please give their efforts careful consideration, and please do not let a failure to plan correctly create an emergency for the City.
Thank you
Blair Miller
)
1 Sabha, Tamer
From:
Sent:
To:
Cc:
Subject:
Colin Bogart
Tuesday, December 5, 2023 1:02 PM
Lyon, Jason; Jones, Justin; Williams, Felicia; Hampton, Tyron Kenebrew, Jerice; Stevenson, Garrett; Sabha, Tamer
MSC 12/5 Public Comment - Agenda Item 1 - Support for 100% Carbon Free Electricity by 2030
CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you frnowthe content is safe. Report phish using the Phish Alert Button. Learn more....
Dear MSC Councilmembers,
My name is Colin Bogart and I am a resident of Pasadena District 1.1 urge you to require that the Integrated Resource Plan be submitted with a plan that will achieve 100% carbon free electricity by 2030. We've made a lot of progress so far and I really appreciate that you have asked PWP to do better. Please continue to hold PWP to a high standard. The IRP is too important not to include a clear path to 100% carbon free electricity. Thank you.
Sincerely,
Colin Bogart
Pasadena District 1, 91103
1 Sabha, Tamer
From:
Sent:
To:
Cc:
Subject:
Attachments:
Sam Berndt <,
Tuesday, December 5, 2023 2:32 PM
Kenebrew, Jerice; Stevenson, Garrett; Sabha, Tamer; Lyon, Jason; Jones, Justin; Williams, Felicia; Hampton, Tyron
Pasadena 100 Steering Committee
MSC 12/5 - Agenda Item 1 - Public Comment - Plan for 100% Carbon Free Electricity MSC 12_5 Technical Analysis.pdf
CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you fcnowthe content is safe. Report phish using the Phish Alert Button. Learn more....
Municipal Services Committee,
The 12-5 IRP draft (the "Draft") needs more work in order to be a workable plan for our city's transition to 100% carbon free electric power by December 31, 2030. We in PASADENA 100 have identified six major problems and solutions, below:
1. Problem: The Draft (IRP, RPS Procurement Plan and RPS Enforcement Plan) does not state that Pasadena's plan is to achieve 100% carbon free electric power by the end of 2030.
Solution: State that the plan is 100% carbon free electric power by December 2030 in all 3 documents.
2. Problem; The Draft targets 55% carbon free electricity by 2028, but does not detail what happens between 2028 and 2030.
Solution: Provide detail in the Draft for getting from 55% in 2028 to 100% in 2030.
3. Problem: The Draft relies on a rough unfinished non-optimized scenario.
Solution: Complete plan development as envisioned, using the "building block scenarios" in a 2024 IRP update. Incorporate elements of Scenarios 1-5, model and deliver a useful but flexible plan with regular milestones, evaluation, and transparency to achieve the 2030 goal.
4. Problem: The Draft is back loaded so that the Waypoint in 2028 will be too late to make necessary adjustments.
Solution: Correct the backloading by better distributing resource procurement. Include a 2026 Waypoint for evaluation of all aspects of the plan (not just Goodrich).
5. Problem: Too much delay and aspirational statements.
Solution: In Ql of 2024 implement demand reduction, develop storage, accelerate PPAs. There is no reason to wait 2 years (until 2026) to evaluate how to correct the Goodrich bottleneck. Pilot rate discounts for low- income ratepayers.
6. Problem: The Draft minimizes resources from DER (residential /community solar) and threatens the ONLY incentive for private investment in local generation.
Solution: Remove references in the Draft to changes to NEM that risk destabilizing the market. Scenario #2 needs to be balanced with Scenario #3 in the 2024 modeling by doubling DER and other factors. In Ql 2024, begin a marketing campaign for private investment in rooftop solar, commit to NEM 1, remove caps and other obstacles.
A more detailed technical analysis with in depth suggestions from PASADENA 100 may be found attached. 1 Thanks,
Sam Berndt
On behalf of PASADENA 100
2 RECEiVED
1 -'.0?3 DEC-5 PH 2: 12/5 IRP Problems & Solutions
1. Plan to achieve the 2030 Goal
a. Problem: The IRP Document, RPS Procurement Plan, and RPS Enforcement plan do not plan to bring us to carbon free by 2030. If you do©^,h&vea plan; yoyJA won't get anywhere. The IRP document brings us to 2028. The RPS Procurement Plan and RPS Enforcement plan, the documents that PWP will follow to guide their procurement strategy, only aim to achieve state goals of 60% RPS by 2030.
PWP's RPS Procurement Plan (Figures 1, 4) and RPS Enforcement Plans (Figure 1) only aim and plan to be enforced to achieve 60% RPS by 2030.
ii. Scenario 2, the scenario chosen for the 2028 Waypoint, only aims to achieve 55% carbon free by 2028 (IRP Figure 161), leaving the remaining 45% between 2028 and 2030.
iii. Scenario 2 backloads 1015 MW of resources to be procured in 2030. iv. The IRP, RPS Procurement Plan, and the RPS Enforcement Plan never explicitly states it is the plan to get to 100% by 2030. v. The Environmental Advisory Commission in their 9/25/23 Memo called for: "Reaffirm, in the text of the IRP, that PWP recognizes the City's commitment to sourcing 100 percent of electricity from carbon-free sources by the end of 2030, and that PWP intends to rely on a combination of the scenarios modeled in the IRP to achieve that goal." b. Solution: Update the IRP Document, RPS Procurement Plan and RPS Enforcement Plan to achieve the 2030 goal
i. The RPS Procurement Plan (Figures 1, 4) and the RPS Enforcement Plans (Figure 1) must state the objective of, and list compliance requirements for, 100% carbon free electricity by 2030. ii. Section 22 of IRP must explicitly state that PWP's plan is to achieve 100% carbon free electricity by 2030.
iii. Section 22 of the IRP must show the year to year resource procurement through the end of 2030 (Figure 207).
iv. The IRP, RPS Procurement Plan, and RPS Enforcement Plan should better distribute resource procurement from 2024-2030 (Figure 207). v. The City Council should require PWP to file an extension to make the changes stated above and explicitly state PWP's intention to meet the 2030 goal, and to resolve typos in their IRP document.
1. Public Utilities are permitted a 30 day extension to submit their Integrated Resource Plan as per The California Code of
Regulations, Title 20, Sec. 1342(c) (Page 51). The request for extension must be submitted within 15 days of the submission deadline.
2. PASADENA 100 provided PWP a document containing a list of typos included in the IRP. PWP did not fix these typos in their updated document.
2. Develop a realistic plan to achieve the carbon free goal a. Problem: The scenarios PWP developed were only intended to be "building blocks" to better understand the edge cases of our electric system. It was PWP's intention to merge the results of the scenarios together and re-run the model to develop a more realistic planning strategy. PWP ran out of time to do this. The existing scenarios were never intended to be used as plans. Utilizing Scenarios 1-6 as Pasadena's plan for electricity for the next 20 years is unrealistic.
Merging Scenarios
1. Scenario 2 was modified post-model by PWP (not optimized by the model) to add 400MW of internal commercial solar. Project Sunroof shows Pasadena only has capacity for 389 MW of solar.
2. Scenario 2 does not incentivize DER. Scenario 3 doubles DER.
3. Scenario 2 does not use higher resource adequacy resources such as wind or geothermal. Scenarios 4 and 5 do.
4. Scenario 2 backloads 1015 MW of solar and storage to the year 2030 rather than frontloading the resources.
5. Merging the lessons learned from the scenarios together will create a cost-optimized means of achieving the 2030 goal. ii. Planning for Success (2026 IRP)
1. According to Figure 207 of the IRP, the last year PWP will aim to procure new resources is 2025. This leaves 3 years of PWP doing nothing in terms of procurement until their next IRP update in 2028.A 2026IRP update is strategic and timely.
2. Goodrich is a known problem that needs to be resolved. Waiting until 2026 to update the Power Delivery Master Plan causes a delay in solving the Goodrich Problem.
iii. The Environmental Advisory Commission in their 9/25/23 Memo called for PWP to: "Draft and submit to the Council, on a defined timeline, a formal planning document that outlines, with reasonable specificity, the steps that PWP will take to implement a combination of the modeled scenarios outlined in the IRP and to achieve compliance with the 2030 carbon-free electricity goal."
b. Solution: Finish the job on modeling the optimal resource portfolio to achieve the 2030 goal and develop a plan to get us there.
PWP must be required to develop a 2024 Integrated Resource Plan Update which merges scenarios 1-5 into a set of more realistic scenarios which is then modeled to optimize the resource portfolio needed to achieve 100% carbon free electricity by 2030.
1. PWP must update their RPS Procurement Plan and RPS
Enforcement Plan to comply with the 2024 IRP Update
ii. PWP must be required to develop a 2024 IRP Implementation Plan, following the 2024 Integrated Resource Plan, to develop a realistic plan with a timeline, milestones, performance metrics, and accountability to achieve the 2030 carbon free goal.
iii. The 2026 Waypoint should be a revised Integrated Resource Plan, similar to how PWP completed a 2021 IRP update following the 2018 IRP. iv. The Power Delivery Master Plan (PDMP) should be updated immediately to address the Goodrich constraint, rather than waiting until 2026.
3. Incentivize DER
a. Problem: PWP plans to investigate modifying their Net Energy Metering (NEM) program.
DER provides resilience and resources to the electric grid and reduces overall demand.
ii. Net Energy Metering (NEM) is the ONLY incentive program in Pasadena that enables property owners to receive a return on investment for their solar installation. PWP currently utilizes NEM 1.0 which provides significant benefit to private investors making rooftop solar a worthwhile investment. Jurisdictions that have abandoned NEM 1 and 2 have shown sharp drops in private investment in rooftop solar.
iii. PWP is planning on investigating updates to NEM that would negatively influence investors willingness to invest in rooftop solar. (Section 6.1.2).
Instability in incentives has been shown to reduce private investment. iv. PWP will be investigating updates to NEM during their Cost of Service Study (Supplemental on Information 2023 Power IRP Addendum, Section 2) This confuses rate equity with DER, a narrative favored by opponents of rooftop solar.
b. Solution: Remove destabilizing mentions of changing the current NEM incentive and seek additional means of incentivizing DER,
i. PWP must remove destabilizing mentions of changing the current NEM incentive for private investment in rooftop solar in the IRP and should commit to a plan for increasing rooftop solar using the current NEM incentive plus education/marketing, easing permitting and removing caps on private investment, beginning in the first quarter of 2024.