Sabha, Tamer
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Tuesday, August 27, 2024 2:32 PM
Iraheta, Alba; Jomsky, Mark; Rabies, Sandra; Sabha, Tamer; McMillan, Acquanette (Netta); Kenebrew, Jerice; Soo, Christine; hlaskett, John FW: The Optimized Strategic Plan and Agenda Item #2
P100 Position Paper_DER081924.pdf
From: Cynthia Cannady •
Sent: Tuesday, August 27, 2024 2:30:25 PM (UTC-08:00) Pacific Time (US & Canada) To: cityclerk <[email protected]>
Subject: The Optimized Strategic Plan and Agenda Item #2 You don't often get email fromLearn why this is important 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. For more information about the Phish Alert Button view article "KB0010263" on the DolT portal.
August 27, 2024
For Agenda Item #2
Dear Councilmembers of the Municipal Services Committee:
I write to you as a member of the Technical Advisory Panel for the Optimized Strategic Plan (OSP), working in collaboration with PWP and its consultants, E3. I also write as chairperson of the PASADENA 100 Coalition, a coalition of 22 non-profit, non-partisan organizations and hundreds of Pasadena residents who are deeply concerned about the climate crisis.
On August 19, PASADENA 100 submitted to PWP a position paper on rooftop solar and its critical role in the success of our transition to carbon free electric power. A copy of that document is attached. We respectfully ask you to give it your thoughtful consideration.
In short, rooftop solar is an essential part of the transition to carbon free electric power. Local power that we can control is important for our city's energy security and resilience. Rooftop solar is a form of what is called Distributed Energy Resources (DER) as opposed to Centralized Generation which is electricity generated remotely, sometimes at great distances, and imported into Pasadena on long distance transmission lines. It sounds like it should be the other way, but DER means local. In our context, the most important DER is solar installations on roofs, parking lots and other structures.
Both DER and imported sources of renewable energy are important. We need to do everything we can to get more of both. For the near future, imported electricity will provide most of our supply. But, as the IRP explicitly recognized, a major increase in DERs and storage is important in order to meet our 100% by 2030 goal.
There are 7 points of action. Pasadena should:
1 1. Publicly reaffirm its commitment to its current progressive net energy metering system, make sure that the public is well-informed about it, and keep it in place for 10 years.
2. Set an aggressive goal for distributed solar and assign responsibilities within PWP for achieving this goal. We believe that 100 MW by 2030 is an achievable goal.
3. Build energy storage within Pasadena, both publicly and privately owned, to align with our solar goal. Build resilience and energy security for our city.
4. Improve our currently dysfunctional solar permitting process and make it compliant with California law.
5. Adopt a more sensible policy governing the maximum allowable size for solar installations. Let residents plan for their future!
6. Identify all public buildings that can have solar and set a good example for the public by installing. Make solar a point of pride for our city staff and residents.
7. Take real equity actions to help all Pasadenans reduce their utility bills with rooftop solar, through community solar projects and incentives and subsidies for renters and retired property owners.
United, collaborative and proactive action has never been more important than it is today, as we daily experience the climate crisis. Let's be serious about harnessing the power of the sun right here at home.
Cynthia Cannady
for PASADENA 100
2 Actions Required to Advance Pasadena's Plans for Distributed Solar PASADENA 100
August 19, 2024
Preamble
The planning basis for Pasadena's 2023 IRP includes a load forecast with assumptions relating to current and future levels of distributed energy resources (DER), growing from 23 MW in 2022 to 46 MW by 2030. This equated to doubling over eight years at its current rate of investment and should be considered the absolute minimum level for Pasadena (we are currently at 26 MW according to PWP's latest tracking report). The IRP also underscored the importance of having generation/energy storage capacity within the PWP domain due to limitations in Pasadena's grid connection to CAISO. Pasadena has historically benefited by having its own generating resources independent from CAISO. Expanding Pasadena's distributed solar capacity, and pairing it with local energy storage, will provide additional resilience and energy security by strengthening our ability to react to CAISO grid disruptions, and meet electrical demands that exceed the capacity of our grid connection.
PWP's recently launched tracker states that "It is expected the distributed energy resource installations in Pasadena will increase dramatically in the future as PWP continues to implement the 2023 IRP." PASADENA 100 is hopeful that this will be the case, but it requires the City to commit to a progressive policy stance by adopting the following measures.
1. Restate PWP's commitment to its current progressive "net energy metering" (NEM) policy and to keeping it in place for the next 10 years. Without this public commitment, achievement of even our minimum distributed solar goals is in jeopardy.
PWP's current NEM policy is one that encourages residential and business investment in solar infrastructure. However, the recent adoption by Investor-Owned Utilities of NEM3 has had a negative impact on rooftop solar in California, paring down the number of industry players, reducing competition, contributing to the recent bankruptcy of one of the largest California solar installers, and slowing the level of investment. Naturally, this has created uncertainties as to PWP's future intentions, no doubt dampening solar investment resolve and weakening the prospects for solar companies doing business in Pasadena. There is also some public confusion about what rules apply in Pasadena.
2. Set an aggressive goal for distributed solar and assign responsibilities within PWP for achieving this goal. We believe that reaching at least 100MW by 2030 is an attainable goal, with at least 75% of the investment coming from private citizens and businesses.
As noted above, the 2023 IRP assumed that distributed solar resources would double from its 2022 level to about 46MW. Additional scenarios explored dramatically higher levels of distributed solar (100s of MWs) within PWP's service area, but also assumed that the installed capacity would need to be matched or exceeded by battery storage PASADENA 100 DER Position Paper 0819241
capacity also located within the PWP service area. Estimates of available rooftop areas appear to indicate rooftop solar potential >300MW so we are not limited in this regard.
Achievement of this goal will depend on a public information and marketing "Leadership Campaign" so that residents and commercial property owners are informed of the goal of the campaign, Pasadena's NEM incentives, the return on investment for solar investors, and affordability options. Residents and commercial property owners should understand that their participation will be supported by Pasadena's leadership.
3. Build energy storage capacity within Pasadena to align with an aggressive distributed solar goal for 2030 and beyond. Supporting the growth of distributed solar within Pasadena needs to be paired with a strategy to build energy storage infrastructure within PWP's domain. This is required so that the surplus solar energy generated during times when PWP's contracted resources are already meeting customer demands isn't wasted ("curtailment"). PWP recently announced plans to build 25MW of energy storage capacity - a welcome step forward. Technologies beyond Li Ion batteries are beginning to emerge and should be considered. Pasadena's storage strategy could also include incentives for private investor purchase of batteries and neighborhood microgrids with storage.
4. Make Pasadena's process for distributed solar permitting fast and efficient for all stakeholders, compliant with CA legal requirements and coordinated across city departments. One of the barriers to expanding distributed solar has involved the permitting process. California legislation (the Solar Access Act, SB 379) has mandated the use of an online permitting process by all utilities - a requirement that Pasadena was supposed to have met by September 30, 2023. Instead of adapting the free Solar App+ software developed by NREL for this purpose, Pasadena elected to develop its own software, but it appears that it is still not working properly, causing delays and additional cost for installers and property owners. Coordination among different city departments will be essential in making solar permitting a user-friendly process (e.g., Planning, Public Works, IT, Finance, PWP).
5. Adopt a more sensible policy governing the maximum allowable size for solar installations. PWP currently places restrictions on the maximum size for distributed solar installations, limiting size to match current electrical consumption. Constraints like this do not address the needs of customers who are planning, in the near term, to electrify home heating and appliances and/or switch to an EV. Also, potential generation sources with large roof areas should be maximized to achieve Pasadena's distributed solar goals.
6. Perform an assessment to determine the most economically viable public sites for distributed solar within Pasadena. Public buildings and public spaces, including PUSD, PC and Rose Bowl sites, represent a resource that could be utilized as distributed solar PASADENA 100 DER Position Paper 0819242
generation sites. City staff should list all public buildings and spaces, assess physical and economic viability and fully or partially fund solar installation.
7. Encourage development of community solar projects, and urgently identify ways for renters and low-income property owners to enjoy the economic benefits of investing in distributed solar in a time of rising rates. Pasadena comprises a diverse community of residents, businesses and institutions, property owners and renters, some of which do not have the resources to invest in distributed solar installations. There is a growing interest in community solar projects, by subscribing to solar power generated from remote locations, as well as nearby businesses and/or public buildings/spaces. Some of these programs may qualify for federal and/or state funding.
Pasadena could also consider low to middle income incentive programs to expand the affordability and adoption of solar technologies so that all Pasadena residents can participate in offsetting some portion of their electrical usage.
With all the above considered, having a much larger distributed solar resource for PWPto rely on will likely require policies to allow PWP to manage the resource in a manner that provides optimal benefit to the City. The 2023 IRP stressed that, beyond having an impact on daytime energy demands (i.e., behind the meter usage), the dispatchability of these distributed resources and any associated energy storage (by PWP) is an important consideration.
PWP should outline their plans to balance supply and demand as it relates to these resources.
These may include centralized energy storage, advanced metering infrastructure, demand reduction, time of use incentives, dispatching behind-the-meter storage, vehicle-to-grid and other technologies.
PASADENA 100 DER Position Paper 0819243